Document oQ36YaGx4K846m9KyXMK7G1o
This letter is in response to Mr. Leonard J. Renner's letter of October 27, 1992 regarding the above OSHA referral.
As the Director of Industrial Hygiene for Saint-Gobain Corporation, the parent company of CertainTeed, I appreciate the opportunity to respond to Mr. Renner's letter, regarding asbestos cement (A/C) pipe adapters manufactured by CertainTeed.
The adapters referred to in Mr. Renner's letter are manufactured at CertainTeed's only remaining A/C pipe production facility in Riverside, California. A pipe adapter is a product made from an asbestos cement matrix which is cured to a hardness equivalent to that of concrete. Under normal conditions of use and designed purpose this product will not release asbestos, as it is not normally drilled or sawed. The intended purpose of a pipe adaptor in it's final manufactured shape and form is used to join A/C Pipe to PVC Pipe.
In a recent visit to the plant, I reviewed the labeling procedure for all the A/C products, including pipe adapters. Normally, twenty to fifty of the adapters, depending on their size, are shipped in a cardboard box on a pallet. Two labels, identifying the adapters as being an asbestos-containing product are placed on two sides of the box as well as on the top flaps prior to storage in the storage yard. Photographs of a typical box as it would be shipped from our facility are included in Attachment I Photos 1 and 2. Samples of the labels are included in Attachment II.
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CTD033452
Mr. George J. Tomchick, JR. November 23, 1992 Page 2
We have, over the years had some problems with labels weathering, fading and falling off, as the labels are exposed to the elements while in storage. However in more recent times we have corrected this problem with a stronger label adhesive. In Attachment III Photo 3, the adapters contained in the weathered cardboard on the pallet to the left were manufactured January 30, 1990. Note the labels are still intact almost two years later.
Without seeing the cardboard container or the contents, I have no explanation as to why the container in question did not contain a label at the time of the inspection in the State of Washington. Perhaps the box had been dismantled, lost its label or the adapters were transferred from the original shipping carton.
As you can see from the photos (Attachment IV - Photos 4 and 5)
the size and design of the adapters makes labeling each piece
difficult. The grooves both on the inside and outside of each
adaptor leaves only a very small area to apply a label.
Since
this referral, we have made the decision to apply labels to each
individual pipe adapter at the time of manufacture. Should these
labels become unglued, we will also continue the current
practice of labeling the outside of the cardboard container.
As a further note, CertainTeed, with each shipment includes a packet of information which is given to the truck driver for delivery to the consignee with the load. An example of this packet and the contents are attached (Attachment V). This packet contains the following:
A. Envelope (with specific instructions printed on the outside)
B. Bill of Lading (stapled to the outside) C. Load Order D. An MSDS for FLUID-TITE Asbestos Cement Pipe and Fittings E. A Booklet entitled "How To Install A/C Utilizing Closure
Couplings & Closure Lengths"
In addition, our sales representatives distribute two brochures to each customer. These brochures are also available to anyone upon request:
"Recommended Work Practices for A/C Pipe - A/C Pipe Producers Association" (as referenced on the "Caution" label) -
Attachment VI. "CertainTeed A/C Pressure Installation Guide - Distribution
and Fluid Transmission Pipe Systems" - Attachment VII.
CTD033453
Mr. George J. Tomchick, Jr. November 23, 1992 Page 3
Please be advised, due to economic situations, CertainTeed Corporation will within the next several months be closing the Riverside facility and leaving the asbestos cement pipe business. Be assured that we will continue to comply with all of the OSHA Hazard Communication regulations until our supply of A/C products is completely exhausted. Saint-Gobain and CertainTeed Corporations endeavor, in all of our product lines to assure the safety and health of not only our employees, but also of the end-users of our products. We appreciate OSHA and the State of Washington Division of Safety and Health alerting us to this situation and hope that the correction documented here will be to the satisfaction of both agencies, and will serve to protect the users of CertainTeed products. I appreciate your time and effort and look forward to your response. If you have any questions concerning this matter please contact me at (215)341-7713.
danis W. Reynolds Director, Industrial Hygiene
c: John McGinley: VP, PPG: CertainTeed - VF 2125 3B James Burke: Plant Manager PPG - Riverside 0260
CTD033454
PHOTO 2
ATTACHMENT
I
CTD033455
PHOTO 1
attachment
II
Asbestos Cement Pipe
CAUTION:
Contains asbestos fiber. o Avoid creating dust Breathing asbestos dust can cause
serious bodily harm, including cancer and asbestosis. * When cutting, machining and tapping, always use
recomended wort practices (Refer to Recommended Wort Practice Guide furnished by Manufacturer to your employer]. Do not use Abrasive Disc Saws.
Tubo de Cemento Asbestos
CUIDADO:
Comiene libra da asbestos. s Evite crear poto. La mhatacion de pofvo de asbestos
pueda causar graves dafloa a la salad. mduyendo cancer yatbestoait. * Cuando aa asti cortando. mequinando o tarrajando, siampra aiga las normaa da trabajo raeomandadaa (Rafiarasa a la Guia da Nonnas da Trabajo ftaoomandadaa el fabrieama aa la ha proporcionado a au patrfa) Ab utiAaa Siarraa da Oiaoo AbnsMas.
CertainTeedH CertdeT--4 Cwperedew f.O 6o><60.VarForg.PAt4a? CIS] 341-7000
Asbestos Cement Pipe
Attention:
The asbestos fiber contained in this product does not affect the safety of the drinking water.
E.PA has determined that "asbestos Is not a carcinogen when Ingested."
Further, E.PA states that asbestos cement pipe "should not be reptaoed or its use tSscortinued."
Tubo de Cemento Asbestos
AtenciOn:
e La fibra de asbestos oontenida an este produdo no afecta la seguridad del agua potable,
a La agenda E.P.A. ha daterminado que `el asbestos no causa cdncgr cuando se come."
AdemAs, la agenda E.P.A. dedara que `el tubo de cemento asbestos no debe ser reemplazado o su uso descontinuado."
CertainTeedH
CerlalnTeed Corporation
Pipe & Ptastics Group P.O. Box 660. Valley Forge. PA 19042 (2151341-7000
CTD033456
ATTACHMENT III
PHOTO 3
CTD033457
ATTACHMENT IV
CTD033458
attachment
___Certai^^B
1 46 Pressure 1 Installation Guide
Distribution and Fluid Transmission JDDOOaoa> Doooaao
Piping Systems
CTD033459
ATTACHMENT VI
Recommended
Work Radioes for A/C Pipe
CTD033460
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ATTACHMENT
CTD033461
Material Safety Data Sheet
DATE PREPARED: September 14, 1990
attachment
VD
CertainTeedEI
CertainTeed Corporation P.O. Box 860 Valley Forge. PA 19482 (215) 341-7000 (24 Hour Telephone)
PRODUCT IDENTIFICATION:
FLUID-TITE* Asbestos Cement Pipe and Fittings
Chemical Name: CAS No.: Common Name (s):
Asbestos Cement Pipe None A/C Pipe and Fittings
NFPA Rating: HMIS Rating:
Health Fire Reactivity
00
0
1* 0
0
(See Section 8 for acronyms/definitions.)
Degree of Hazard 0 - Minimal (Insignificant) 1 - Slight 2 - Moderate 3 - Serious (High) 4 - Severe (Extreme) *Chronic Health Effect(s)--See section 5.
1. INGREDIENT INFORMATION:
Chemical Name:
Asbestos (Chrysotile and Crocidolite)
CAS No.:
1332-21-4 (12001-29-5 and 12001-28-4)
Common Name:
Exposure Limits:
OSHA
ACGM TLV
Other
8 hr. PEL - 0.2 fibers
Chrysotile - 2 fibers
None
> 5 um/cc
> 5 um/cc
30 min. EL - 1 fiber
Crocidolite - 0.2 fibers
> 5 um/cc
> 5 um/cc
This chemical is listed on EPA, SARA, Title HI, Section 313 but not Section 302, and is listed on California's
Proposition 65.
Chemical Name: CAS No.: Common Name: Exposure Limits:
Quartz 14808-60-7 Crystalline Silica OSHA PEL Respirable Dust: 0.1 mg/m3
ACGIH TLV Respirable Dust: 0.1 mg/m3
Other None
This chemical is not listed on EPA, SARA, Title III, Section 302 or 313, but Crystalline Silica is listed on California's Proposition 65, with a qualifier for airborne particles of respirable size.
2. PHYSICAL DATA
Boiling Point (F): None Melting Point (F): None Odor None Color: Cement Gray Vapor Density (Air=l): N/A
Specific Gravity (HjO=l): 2.35 Evaporative Rate (ethyl ether=l): N/A Vapor Pressure (mmHg @ 20C): N/A % Volatile by Volume: N/A % Solubility: Negligible
Appearance: Cement gray-colored pipe and fittings
Page I of 4
01-08-0020 9/90
CTD033462
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#* SHIPPER PROVIDED SHORT FORM BILL OF LADING - NOT NEGOTIABLE - DOMESTIC #
PARTIES HERETO AND THEIR ASSIGNS ARE FAMILIAR WITH AND AGREE THAT |-------------------------
THIS BILL OF LADING IS SUBJECT TO:<1> THE TERMS AND CONDITIONS OF |SHIPPERS NO.
HE UNIFORM DOMESTIC STRAIGHT BILL OF LADING AS SET FORTH IN THE 160920537 2
.ATIQNAL MOTOR FREIGHT CLASSIFICATION; AND (2) TARIFFS AND CLASS- |-------------------------
IAFTIlCl/AHTIIOA. UNMS, IN EFFECT ON THE DATE HEREON.
FROM CERTAINTEED CORPORATION AT P.O. BOX 706 RIVERSIDE CA. 92059
(PERMANENT POST OFFICE ADDRESS OF SHIPPER)
----------------------------------------
ROUTING:
I CAR OR | DATE
CONSIGNED TO: MCAFEE-GUTHRIE DESTINATION/SPECIAL INSTRUCTIONS:
ATTACHMENT VB
I TRAILER S| . . . n
C/0 CYPRESS
1301 U. UNION HILLS
PHOENIX
AZ 00000 TO BE PREPAID
DEL 7:00 AM POOL W/PARKSON 0511 6 0629 4' UNITS
1DELIVERY DATE
NO TAX
J 1/17/92
FINAL==053?
SPKG
KIND OF PACKAGE DESCRIPTION OF ARTICLES
WGHT. CLASS
PCS. PIPE, CEMENT, CONTAINING ASBESTOS FIBER (NMFC ITEM 50930) CPLG. PIPE CEMENT CONTAINING ASBESTOS FIBER (NMFC ITEM 51010) CTN RUBBER WASHERS & LUBE
K
IHMHf
*ALL PIPE- --LOAD MUST BE
*
^COVERED TO PROTECT INTERIOR*
*FROM DIESEL CONTAMINATION *
UKUU
TOTAL
WEIGHT
26,852.90 LBS
SUBJECT TO SECT.7 UF CONDITIONS OF APPLICABLE BILL OF LADING,IF THIS SHIPMENT IS TO BE DELIVERED TO CONSIGNEE WITHOUT RECOURSE ON THE CONSIGNOR, THE CONSIGNOR SHALL. SIGN THE FOLLOWING STATEMENT:
CARRIER SHALL NOT MAKE DELIVERY OF THIS SHIPMENT WITHOUT PAYMENT OF FREIGHT AND ALL OTHER LAWFUL CHARGES.
CERTAINTEED CORPORA!ION
RECEIVED IN APFu )RENT GCfQD ORDER- EXCEPTION NOTED I
(SIGNATURE OF CONSIGNOR)
CARRIER PER: /
DA HE:
rli.dAiA1
SHIPPER PER
DATE
CTD033464