Document nomrwqQJx28vLM839DQJ40Ga

FILE NAME: Rockwell (ROCK) DATE: 1983 DOC#: ROCK002 DOCUMENT DESCRIPTION: Inspection Report - Assessment Respecting Asbestos Exposure-Rockwell International ASSESSMENT RESPECTING ASBESTOS EXP05URE ROCKWELL INTERNATIONAL HIGHWAY BRAKE AND TRAILER AXLE DIVISION TILBURY, ONTARIO The follow ing assessment is documented to meet the requirements o f Section 6 (1) o f the Regulation respecting asbestos, Chapter 321 o f the Revised Statutes o f Ontario, 1980. The completion o f this document was achieved with the able assistance o f the following personnel: e Mr. Peter Belanger, Plant Chairman o f Local 1941 o f the UAW, representing hourly employees a t the Tilbury p lan t; Mr. Edgar Labonte and Mr. Greg Church, both Health and Safety Committee Members o f Local 1941 o f the UAW; o Mr. Joe Simard, Labour Relations Supervisor at T ilbu ry; e Mr. Dan la n ic e llo , Manager, Industrial Relations at T ilbury; a Mr. Mike Berthiaume, D irector o f Manufacturing at Troy, Michigan, and former Plant Manager a t T ilbury. The input from the various parties was greatly appreciated. I t is a concensus th at th is assessment indicates Rockwell has s a t is fie d the requirement and the intent of the L e g isla tio n . RWI 000067 Bankhead_Pitfs' Exhibit no 0450 p g i W ORKBOOK FOR D ESIG N A TED SU B ST A N C E A SSE S SM E N T S SUBSTANCE: ASBESTOS (CHRYSOTILE) DATE: AUGUST 22, 1983 COMPANY NAME: ROCKWELL INTERNATIONAL____________________________ _ DEPARTMENT/ OPERATION(S): HIGHWAY BRAKE & TRAILER AXLE DIVISION LOCATION(S)- TILBURY, ONTARIO ASSESSMENT PREPARED BY: y . j . L0NG TITLE: REGIONAL MANAGER, SAFETY ENGINEERING, TROY, MICHIGAN DATE PREPARED: AUGUST 22, 1983 RWI 000068 Bankhead_Pltfs' Exhibit no. 0450 pg2 APPLICATION -- WORKSHEET 1: IS THE DESIGNATED SUBSTANCE PRESENT? 1. (a) Do any of the processes or activities or situations listed in the Appendix, or other information sources, indicate that the substance is or may be present? YES NO . (b) Do any data sheets or information from your suppliers indicate the presence of the substance? YES NOD 2. If substance is present, indicate the department where it is used, nature of the use (be. direct or indirect) and the quantity purchased per month or year: Product Name BRAKE LININGS {CHRYS0TILE ASBESTOS) Department RIVET & GRIND ASSEMBLY SHIPPING & RECEIVING QUALITY CONTROL WAREHOUSING How Used? D ire c t/In d ire c t DIRECT ' DIRECT INDIRECT , INDIRECT INDIRECT CENTRAL PAYOUT CAROUSEL LIFT TRUCK DRIVER INDIRECT INDIRECT INDIRECT THESE FIGURES ARE FOR THE MONTH OF AUGUST, 1983 11 II u 11 " " JANUARY, 1986 Quantity Per Month/Year * . 140,000 TOTAL/MO . 80,000/M0 ARE GROUND . 17,200 ARE NON ASBESTOS LININGS . 400 OF THE 30,000 ARE NON ASBESTOS * * . 1C0.0C0/T0TAL/M0 * * . 40,000 ARE GR0UNI ** 40% OF TOTAL LININGS ARE NONASBESTOS CONCLUSIONS Read statements and check applicable box: Substance not present anywhere in workplace; regulation does not apply. No Assessment needed. Processes/activities have been identified where substance present. Proceed to worksheet 2. RW1 000069 Bankhead_Pltfs' Exhibit no 0450 pg3 APPLICATION - WORKSHEET 2: IS WORKER EXPOSURE LIKELY? 1. In what form does the substance enter the plant? SOLID. & SOME DUST IN THE BOXES. Product title: BRAKE LININGS CARDBOARD BOXES 25 LININGS EACH OR Type of container: STRETCHED WRAPPED, Size of Container: 50 LININGS EACH i 2. Is this form altered during U9e or in the operation? YES ixl N O D [f YES. indicate altered farm- 57% OF LININGS ARE GROUND; THIS GENERATES DUST 3 is there a possibility of the sub stance being released into the workplace environment during normal YES NO D USB? If YES. indicate the stage of the operation or areas where this can occur. INSPECTION, MATERIAL HANDLING, RIVETING, GRINDING, BRAKE ASSEMBLY BENCH. STACKING AND BANDING.___________________________________________________________ 4 If YES, to Question 3, specify the job functions and approximate number of employees who might be exposed: (see addendum #1) fob Function Number of Employees RIVETERS & GRINDERS 10 OVER 3 SHIFTS If YES, to Question 3. indicate how workers could be exposed: Inhalation Ingestion Skin absorption C l Skin contact D r. If NO. to Question 3. is there a likelihood of escape due to leaks, accidents, etc.? Are workers likely to be exposed? YES O NO Q YES CH NO EH CONCLUSIONS .'ire there any activities/situations where exposure by any route is likely? YES 1x3 NO Q if NO, no further action is necessary. Date completed___________________________________________ f YES, an assessment is necessary. -- Proceed to Section III ' -'etc: If protection against exposure has been left up to some engineermg control measure which can faiL or deteriorate for any reason, or to a work/hyglene practice, an assessment is necessary. -- Proceed to Section IB. RWI 000070 Bankhead_Pltfs' Exhibit no. 0450 pg4 ASSESSM ENT - WORKSHEET 3: PROCESS DESCRIPTION NAME OF PRO CESS:___________ BRAKE MANUFACTURE ._______________________ Process Flow* t. 2. 3. 4. Description Linings received in sealed cardboard boxes on stretch wrapped p a lle ts . Likely Exposure Yes/No No Very few boxes are opened fo r No physical inspection. Weigh count done on a ll No incoming boxes. Boxes, some open, most sealed No stored in racks. G. 7. * Add ) >xcs as necessary Boxes, some open, most sealed No stored in racks. A ll boxes are opened, linings Yes removed, and riveted to steel brake shoes. Some dust is generated and collected by down d ra ft tables and suction hose. Approximately 57Z o f che shoes Yes are mounted on a grinder and the outside of the linings are ground to a s p e c ific radius. Dust is generated and co llectec in exhaust system. RWI 000071 Bankhead_Pltfs' Exhibit no. 0450 pg5 f ASSESSM ENT ~ WORKSHEET 3: PROCESS DESCRIPTION NAME OF PROCESS: SRftKF MANUrAfTllRF_________________ '_______________ [Continued) Process Flow* L J. Description Likely Exposure Yes/No Operators vacuum machine areas Ves a fte r each s h i f t . Cartons are vacuumed a fter emptying. Vacuum-, hose is attached to bag house. Some dust is disturbed.' Dust from collector, hopper is Yes augered into p la s tic bags inside wooden boxes. Bags are sealed and labeled. Boxes are picked ur by B . F . I . , the Disposal Contraci or and taken to the Ridge la n d fill site-approved certifica tio n No. 3003. Some dust can escape i f proper procedures are not followed. Shoes are assembled into a No finished brake u n it, stacked an<i banded on p a lle t s , and sent to stretch wrap. Some dust may escape to the environment. Holding area. No Assemblies are ohysically Mo checked for orooer components. * Add 1oxo* a'' necessary. Holding area No RWI 000072 Bankhead_Pltfs' Exhibit no. 0450 pg6 ASSESSMENT - WORKSHEET 3; PROCESS DESCRIPTION NAME OF PR OCESS:_____________________BRAKE, frlANLOCT-URE. (Continued) Process Flow* ]Q. STOCK ROOM Description Holding area. Likely Exposure Yes/No No 11. carousel FOR PALLETIZING Finished assemblies p a lle tiz e d No fo r shipment. 12. STRETCH WRAP 13. AXLE LINE STORAGE Palletized assemblies are No wrapped in p la s tic (except for Ford and I .H .C .) . Holding area. No SHIPPING PICK-UP 14. * HOLDING AT OLSEN' 15. ir SHIPPING FROM 16. 1 OLSEN'S REWORK IN RIVET 17. AND GRIND * Add tioxe.s as necessary. Palletized assemblies are No transferred to Olsen's Warehouse. Holding area. No * The Olsen operation was abandoned May, 1905. All shipping now done from Rockwell. Palletized Assemblies are No loaded onto highway vehicles fo r shipment. Repairing defective brakes. - RWI 000073 Bankhead_Pltfs' Exhibit no. 0450 pg7 ASSESSMENT - WORKSHEET 4: EXISTING CONTROLS Process Flow Stage Control Description Problems/Recommendations RIVET AND GRIND ROOM Engineering Controls: . Wheelabrator 95 u nit bag house complete with duct to exhaust asbestos dust from 2 rrinders and 7 r iv e t machines . Downdraft tables at each riveter. . Rivet and Grind Room under constant negative a ir pressure . Rework table exhausted to bajbouse . Failu re to open damper . Broken exhaust fan belts . Loss o f power to exhaust motor . Broken or poorly seated bags . Fire in baghouse or ducts . Clogged ducts A ll the above are monitored by reading the manometer d a ily . The ba^s in the baghouse are OuDont 90521 F119 cotton bags. . Failure to secure p la s tic bar at end of auger. Work P ractices: - Personal Protective Equipment . Sometimes sweeping is done during r iv e t and Grind Room clean-up. This nractice must stop and be . Coveralls replaced by a vacuum clean-up . Respirators-3M No.8710 n ra ctice . *?urchasing Department Disposable Dust Masks. is now searching fo r eauiament The Aooroval No. is 3M-TC-21C-132. . to reolace the unsatisfactory portable shop vacs o rig in a lly - Baghouse inspection and ' purchased to correct This problem. maintenance done quar- te r ly by Endure, F ilte r * Vacuum units were ourchased and Care D ivisio n . have been in use for a couple of - Daily manometer reading years. - No smoking or eating in r iv e t and grind or assembly areas - Daily s h ift clean-up - Reporting dusty boxes for corrective action - Prooer disposal o f dinc\ clo th in g , dust and marked bags. - Use o f senarate lockers for work & str e e t clothe s - Visual inspection of ducts and repairs as necessary. RWI 000074 Bankhead_Pltfs' Exhibit no. 0450 pg8 ASSESSMENT - WORKSHEET 4 - EXISTING CONTROLS (Cont'd) Pi-ri '.ass Fin v Stn Control Description Problems/Recommendations Hygiene Facilities and Practices: RIi/ET AND GRIND . - Coveralls supplied & cleaned by Work Wear . No one leaves the plant in coveral 1s . Separate lunch f a c ilit y east of cafeteria . No smoking allowed in Rivet and Grind Room or Assembly . areas . Employees encouraged to wash up before eating or drinking. Supply separate d ir ty clothe:; locker and clean clothes locker separated by a shower room, with an adja cent eating area. For Rivet and Grind Room employees only. Training/Information: . New operators trained by foreman * . Edgar Labonte, Greg Church, Pete Belanger trained by W. Long in the use o f Dupont monitoring equipment, . Labonte, Church & Simard attended "Health Hazards in the Workplace" seminar in - Toronto, June 14-15, 1983. . Stewards, Chairman, President Committeemen, and Safety Committee have been to Troy T/C to learn microscope' tech niques. Emergency Procedures/Equipment: . Exhaust equipment to be shut down i f system f a i l s . Foreman to contact Joe Simard PersonaP^rokeclrCe Equipment: . A ll personnel (in clu d . v is ito ns) in Rivet and Grind Room must wear respirators-3M-N0. 8710 -Chosen by employees from (throw away masks) several offered. . Coveralls , Eye protection . Safety shoes . Gloves | * J . G tle y , R. Arne]], and R. S t . John have been trained. RWI 000075 Bankhead_Pltfs' Exhibit no. 0450 pg9 ASSESSMENT - WORKSHEET 5: JOB EXPOSURE ANALYSIS Procos flow St.'RO t. 1. Job Title Total Number oi Employees Tasks Where Exposure Likely Duration Hra. Per Week PPE Req'd. To be Used fiO','0 K SALVAGE AND Knocking out riv e ts and * _ Yes i REPAIR replacing defective 3M-8710 lin in g s . Respirator * ? 17 Hpjt urs - Contracterai he urs - not n ecessarily actijal hoi|rs worked for 40 Hour Veek .17 HO1urs - C on tractiral he urs - not n ecessarily actual hodrs worked for 48 Hour Week CONCLUSIONS Job:; :asks to be noted particularly during walk through survey: . RIVETERS . GRINDERS RWI 000076 Bankhead_Pltfs' Exhibit no 0450 pg10 ASSESSMENT -- WORKSHEET 6: HEALTH EFFECTS 1 Any reported health effects? ff so, describe. NO 2. Any current Medical Program? If so. describe. . Pre-employment medical for a ll new h ires includes PA & la te r a l x-rays and pulmonary function te sts including PVC & FEV2 " . Annual medicals fo r a ll employees to include x-rays & pulmonary func tion tests w ill begin in 1986. . Preplacement training for health education. . Asbestos exposure records are retained for 40 years a f t e r plant closure ,i. Previous exposure monitoring results? If so. describe. * . Regular monthly sampling done by Edgar Labonte with Dupont vacuum pump and 37mm diameter mi 1lipore f i l t e r . Samples are counted at R .I . Tech Center by Murtis Hartry and reported back to the p lan t. . W. Long samples annually as a check on E. labonte's sampling. . The Ontario M inistry of Health conducted comprehensive sampling in 1981 (Refer to the asbestos f i l e in Personnel fo r sample re su lts). . Since brake production methods have remained e s s e n tia lly the same over the years, the results in the asbestos f ile s t i l l apply. Rockwell commissioned McLaren & Associates in 1980 to do a complete asbestos environmental study. Results are a v a ila b le in Personnel. . Sampling fo r asbestos has been done regularly since 1973. . 01 1e.y, R. Arnel & R. S t . John have since been trained to take asbestos samples. CONCLUSIONS Health effects known at this stage: YES O NO 03 This plant was acquired by Rockwell in 1959 and has been in operation for the past 24 years. The latency period fo r asbestos related disease is generally in excess o f 20 years. Further information required: YES NO O Regular monitoring w ill continue and we w ill do what we can to continue to reduce the fib e r count. RWI 000077 Bankhead_Pltfs' Exhibit no. 0450 pg11 T,OCATION: ASSESSMENT - WORKSHEET 7: FLOOR PLAN TILBURY, ONTARIO naTF. AUGUST 22, 1983 DIMENSIONS: L __________ W __________ H __________ WORK STATION -- enter number Erotn lob Title - Worksheet 5 A EXPOSURE SOURCE -- enter number from Process Flow - Worksheet 3 VENTILATION -- enter 1 for local exhaust & 3 for general ventilation RW! 000078 Bankhead_P1tfs' Exhibit no. 0450 pg12 Bankhead_Pltfs' Exhibit no. 0450 pg13 ASSESSMENT - WORKSHEET 5: WALK THROUGH -dence of Contamination: ADDITIONAL NOTES ON; . Some dust on ductwork in Rivet and Grind Room. i .iygieue facilities and Vork Practices: An A.R. has been prepared to revise the ^ c k e r room, shower, and eating f a c i l i t i e s fo r the Rivet and Grind Room employees. See Engineering for layouts. ntllatlou Systems: The exhaust system - Baghouse and Ductwork operate e ff ic ie n t ly as evidenced by the constant low fib er counts. Quarterly inspection and maintenance o f the system is done by Endure, F ilt e r Care D iv isio n . jfagt) Facilities. .Storage o f raw m aterials nor the finished product present any health problems. Low fib e r counts have been recorded in a ll these areas. RW1 000080 Bankhead_Pltfs' Exhibit no. 0450 pg14 ASSESSMENT - WORKSHEET 8: WALK THROUGH (Cont'd) Dispensing Procedures: ADDITIONAL NOTES ON: . Sealed and marked p la s tic bags in wooden boxes are used to handle a11the waste products.. . B .F .I . transports a ll asbestos scrap to the Ridge Landfill s it e . Housekeeping: . Generally very good. . Rivet and grind room employees vacuum a fte r each. sh.i;ft. Personal Protective Equipment: . Rivet and Grind Room employees wear co v e ra lls, 3M disposable resp irato rs, safety g la s s e s , safety shoes and gloves in certain operations. Emergency Facilities.' ProceduresI he manometer was moved from the baghouse to the Rivet and Grind Room where i t can be read anytime during a s h if t . In the event of exhaust fa ilu re maintenance and personnel must be n o tified immediately. The s itu ta tio n w ill be assessed and a decision made- on the merits of each case. 1 I RWI 000081 Bankhead_Pltfs' Exhibit no. 0450 pg15 ASSESSMENT -- WORKSHEET 9; WALK THROUGH CONCLUSIONS 1(a) Were any areas found where controls are required or where existing controls YES EG NO may require improvement? 1(b) if YES, Indicate the areas where the controls may be required or where existing controls may require improvement. AREA SUGGESTED IMPROVEMENT Rivet and Grind Room . Continue to maintain the quarterly inspection o f the exhaust system. . Continue to maintain a good housekeeping program. '.(a) Personal exposure monitoring is required. YES Ixp NO CD 2 (b) if YES, indicate where: . Continue the program to monitor employee exposure in the Rivet and Grind Room on a monthly b asis. . Continue to sample other areas of the plant on a periodic basis to ensure exposure is maintained well below the allowable lim it. 3. indicate any workers for whom medical testing and/or examinations may be required: A ll the riveters and grinders. RW1 000082 Bankhead Pltfs' Exhibit no. 0450 pg16 CO N CIISIO N S: WORKSHEET 10: IS A CONTROL PROGRAM NECESSARY' !CONCLUSION I: NO WORKER'S HEALTH MAY BE AFFECTED. CONCLUSION H: A WORKER'S HEALTH MAY BE AFFECTED. . Exhaust ven tilatio n in the Rivet and Grind Room generally works w e ll. . The Baghouse inspection is done quarterly by Endure--F ilte r Care Division . There are currently no reported health problems. . The asbestos sampling program w ill continue as i t has in the past. . This ongoing program recognizes the presence o f asbestos in the a i r , but i t w ill maintain the employee exposure to the lowest possible concentrations. CONCLUSION III: FURTHER ADVICE TESTS REQUIRED. DATE............................................................. SIGNED RWI 000083 Bankhead_Pltfs' Exhibit no. 0450 pg17 ADDENDUM #1 TO THE ASSESSMENT RESPECTING ASBESTOS EXPOSURE - TILBURY ASSUMPTIONS: There is no d e fin itio n o f the word "exposure" in any o f the m aterial that constitutes the regulation respecting asbestos. The fib e r counting procedure currently in use has d e fin ite accuracy lim itatio n s when the very minute concentrations are reached. Accordingly, for the purpose o f th is assessment, we have chosen to accept the I.A .P .A . (Industrial Accident Prevention Assocation) guidelines for exposure as being .5 fib e r per cubic centimeter. The various actions required by the assessment and control program are predicated on that I .A .P .A . d e fin itio n . RWI 000084 Bankhead_Pltfs' Exhibit no. 0450 pg18 ADDENDUM #2 - To th e Assessment R especting Asbestos Exposure - T ilb u ry Many changes in the personnel involved with the development of this assessment have taken place since August, 1983. They should be lis te d in the in te re st of continuity o f e ffo r t with th is document. 1. Plant Manager Changes: Mr. Dick Quaid replaced Mike Berthiaume in October, 1983. . Mr. John Thompson, current Plant Manager, assumed those duties February, 1985. ` 2. Personnel Manager Changes: Mr. G. W illis replaced Mr. 0. Ia n ic e llo in March, 1984. 3. Other Changes: . Mr. S. Travis replaced Mr. P. Belanger as Plant Chairman of Local 1941 of the U.A.VJ. in Ju ly , 1985. Mssrs. J . O tle y , R. Arnel and R. S t . John are the current Health and Safety Committee members o f Local 1941 of the U.A.W. Union. February, 1985 RWI 000085 Bankhead Pltfs' Exhibit no. 0450 pg19