Document oDoKK6VLa8xDYbGdQerrozkG7

nr. mi E. I. du Pont oe Nemours & Company WH.MINGTON.-OeUAWARE 19838 TEXTILE FIVERS OEFARTMENT cc: J. A. ? nan /4 00030 N. K. Waiters - Emp. Eel. T. W. Harmvan - Legal J. W. Iwert - Louviers ~ W. L Pollock - Louviers Engineering Superintendents M. E. Sabla - Cape Fear T. J. Hampton - Spruance S. A. Nunnery - Camden E. L. Long - Kinston G. B. Kirkpatrick - Old Hickory J. O. Exley - Martinsville N. C. Hrnjez - Seaford L. B. Wilson, Jr. - Chestnut Run E. M. O'Donnell - Waynesboro H. L. ADAM EMPLOYEE RELATIONS NEMOURS 12452 November 25, 1975 PROPOSED ASBESTOS STANDARD We have reviewed the proposed standard and wish to make the following comments: Comment #1 The standard must be changed or modified to allow for work places of non-fixed nature. . . Discussion . As now written,, the monitoring requirement of three months after a measurement in excess of the limit is impractical since most f-our jobs don't last nearly that-long.i.-.. . . } The regulated area requirement is extremely impractical " and could not be followed in the minor maintenance jobs where only one to tv/o people are involved for 10-15 ' minutes to remove or replace asbestos insulation. As . a matter of fact, the concept of a regulated area seems to only be applicable to shop areas or manufacturing . _ assignments, not to maintenance type work. The requirement for engineering controls cannot be practically pursued on small maintenance jobs and it should be so noted in the standard. ' DUP 0903757 BETTER THING* FOR BETTER LIVING . . . THROUGH CHCMtSTmr SC-DP-04915 Proposal ' 00031 Write a standard relating to plant maintenance type work or let the construction standard (to be written) cover this type work. Comment#2 To our best knowledge, no data has been published to y '-- support the exposure limits; as a general rule arbitrary . tightening standards should be challenged. Discussion We in Textile Fibers do not have the data to challenge the proposed exposure levels, however, the current standard promulgated in 1972 calls for 2. 0 vs. proposed 0.5 fiber/cc, however, the additional cost requires the objection be raised and satisfactorily answered. Has OSHA developed a reliable means of measuring fiber counts this low ? It is our experience that measurements in this area are unreliable. - Proposal Leave level at 2. 0 fibers/cc as now written. Comment #3 The wording change from dust hazard to cancer hazard is not necessary and causes loss of creditability in the standard. Discussion Changes in this standard after compliance has been obtained, lessen the creditability of the standard. What has changed so dramatically from 1972 that it requires a whole new re-education program for the people with a change from warning words to scare tactics? This is inconsistent with the warnings on cigarettes. Proposal Don't refer to cancer, but leave words as they are today. The proposed standard represents a major change from the current standard and to comply will cost the Textile Fibers Department a cne-tirne cost of 51,000,000 and an annual cost of $500,000. This expenditure will probably provide economical justification for major replacement oi our current insulation with non-asbestos insulation I recommend the above comments be presented formally to OSHA as part of our Company's response. ENGINEERING DIVISION JGP/ssb . G. Plasky Engineering A DUP 0903758