Document npzNQ7nK5weGJvGb7B2kY05qX

Inter Office Electrical and Electronics Division January 22, 1980 A. H. Buell* R. P. Burke R. D. Esch R. U. Obringer R. K. Ruth F. E. Tack . G. H. Wolcott C. T. Bulea R. A. Fluck W. A. Lewis A. R. Locker J. Miyaura* G. M. Park A. Tymcryk H. E. Craig R. L. Cummings E. 0. Miller R. C. Semler J. H. Witherspoon Supject: Procedures for Handling Material Containing Asbestos Recentlv the Sandusky ana Lansdale plants were inspected by OSHA as the result of employe complaints of asbestos exposure while working in the powerhouse. ' During the insoection, neither location was sampled for airborne asbestos parti- csis out in both cases asoestos material was identified. One inspection resulted ir a citation being issued with the following violations noted: . 1) Written standard operating procedures governing the selection and use of respirators were not established (1910.12-fb)(1)). The users cf respirators were net instructed and trained in the proper use of respirators and their limitations (1S11.134 (b) (3)'-. Respirators issued f?r the e ~*&&r** . I 7 B.Z T Z,2" S Urt rr.e verier were r.:: `Lear.ec 11910.1 >- iz ' . sive use cf one vcrrcer vere ncc r.c res:;ra::rs usee. r.cre rr.ar disir.feccec after ear:, -use -) Respirators were not stored in a convenient, clean and sanitarv location (1910.134(b)(6)). 5) There were no regular inspections and evaluations to determine the continued effectiveness of the respirator program (1910.134(b)(9)). 61 Persons were assigned to tasks requiring use of respirators and it had not been determined that they were physically able to perform the work and use the equipment, and the user's medical status was not reviewed periodically (1910.134(b)(10)) . eoo? PRODUCED BY FORD SCF-FORD-1789 -2- 7) Initial monitoring was not conducted in such a manner to determine whether every employe's exposure to airborne asbestos fibers is below the prescribed limits (1910.1001(f)(1)). 8) Samples were not collected from areas of a work environment which were representative of airborne concentrations of asbestos fibers which may reach the breathing zone of employes (1910.1001(f)(3) (i)). 9) Caution labels were not affixed to all new materials, mixtures, scrap, waste, debris, or other products containing asbestos fibers, or to their containers which during any reasonable foreseeable use, handling, storage, disposal, processing or transportation could release airborne concentrations of asbestos fibers exceeding prescribed exposure limits (1910.1001(g)(2)(i)). 10) Asbestos waste, scrap, debris, bags, containers, equipment and asbestos - contaminated clothing, consigned for disposal which may produce airborne levels of asbestos fibers in excess of prescribed limits were not collected and disposed of in sealed impermeable bags or other closed, impermeable containers (1910.1001(h)(2)). Due to increasing concern regarding asbestos usage in the work place, it is impera tive that we review existing practices to ensure that established procedures are peing followed in accordance with OSHA regulations and corporate recommendations. A copy of R. L. Wabeke's letter dated January 29, 1979 is attacned outlining corporate staff's recommendation to substitute less hazardous, non-asbestiform materials for asbestos and its products wherever feasible. A list of suppliers of non-asbestos material has been forwarded to all plant safety engineers to assist them in identi fying suitable substitutes. In conjunction with the Plant Engineering Department, all application of asbestlform material should be reviewed anc every effort be mace to reolace it with ar. approved material. It should oe noted to.at whenever asbestifore materiel is remc certain trotecures must be followed as tit lined ir. , retit:. register. The procedures .r.tluce tr.r jse of resptrat tr or usee vnile working vitr. ssoestitrrr material. resrir; estttlisr.ee which induces medical et:ts, fitting, cleaning a: re tors es outlined in 1c 1 . 1 3- . .. candied .r.c dis1.1001 of equioner. w.L |>i,i storage o. res When it is necessary to remove, handle or otherwise expose employes to asbestiforr material, initial air sampling must be conducted by Industrial Hygiene to establish the exposure levels. In May, 1978 all plants were requested tc identify both pro duction and non-producticn uses of asbestlform material and to arrange to have each area monitored by Industrial Hygienes To date, all production uses that were identified have been reviewed by the Corporate Industrial r.ygiene Department. Some non-production uses of asbestlform material have not been monitored due to the infrequency or scheduling of those particular jobs. In order to conduct the initial monitoring, it is essential to make every effort to inform Industrial Hygiene when these non-production jobs will be performed. If monitoring cannot be arranged prior to the operation, precautions must be followed as though the worst conditions exist during the operation. 8007 16C8 PRODUCED BY FORD -3- In consideration of the increased public and employe visibility from recent plant inspections, it is requested that both production and non-production operations be resurveyed with respect to the use of asbestiform materials. A report should be forvarded to our respective offices no later than February 22, 1980 and should include the following information: 1. A listing of all asbestiform material in use within the plant identified by: a) material, b) location, c) application, and a) whether or not it has been monitored by Industrial Hygiene. 2. Provide an historical summary of the steps taken to replace the asbesti form with a substitute material. 3. Provide a separate listing of all maintenance materials, both asbesti form and non-asbestiform, used for the insulation of hot and cold surfaces. "' " " ' 4. Provide a copy of any plant procedure or instruction issued to employes concerning the use and/or handling of asbestiform material. 3 gl Attachments "Inramscior. onI> 8007 1609 PRODUCED BY FORD