Document oed7zZ8556zL0nzy4bMdnQk68

January 09, 1987 OSHA ASBESTOS STANDARD On Juna 20, 1986, tha Occupational Safety and Health Administra tion (OSHA) published its final standards on asbestos. The first, the General Industry Standard, deals with asbestos in the workplace. The other standard addresses asbestos snocuntsrsd on construction vcrk. Under both standards, the Permissible Exposure level (PEL) for aitiwwfrns has been reduced from 2.0 fibers/oc to 0.2 fiber/oc, a ten-fold decrease. The new standards also incorporate an action level of 0.1 fiber/oc for asbestos exposure which triggers duties involving monitoring, medical surveillance, and enplqyee training. The Reynolds policy an asbestos provides that: 1. No new asbestos-containing products should be purchased where there are feasible substitutes. 2. Asbestos-containing materials already in place, and in good repair, should be properly maintained to avoid enployee exposure. 3. All asbestos-containing products in poor repair, or those likely to generate enployee exposure, should be replaced with feasible substitutes, in accordance with approved asbestos removal procedures. 4. If there are no feasible substitutes, (or if asbestos removal would generate unacceptable levels of exposure,) appropriate engineering controls, maintenance procedures, and work practices shall be implemented to prevent erplcyee exposure when handling asbestos-containing material. Since Reynolds Metals Ocrpany no longer purchases asbestos, except in cases there there are no feasible substitutes, such as brake shoes and clutch linings, our primary oonoem is the asbestos that is in place, i.e. pipe and furnace insulation, etc. Recently, a memo from Bill Strain of Central Engineering was sent to plant engineers, asking for a status report and a oost/time esti mate for work that will be required to ensure ocnplianos with the new regulations. Whenever this information is cmpletad, priorities will be established regarding the removal and/or repair of asbestos at each of our facilities. In addition, asbestos contractors are being identified by Corporate Purchasing, to facilitate future asbestos related projects. TXTINER RMC0086285 1 W-100-*S 003601 Industrial Hygiene Bulletin #126 OSHA ASBESTOS STANDARD January 09, 1987 For the most part, asbestos related exposure within Reynolds will fall under the Construction Standard far asbestos, which pertains to projects related to the installation, construction, alteration, repair, maintenance, transportation, and demolition of asbestoscontaining materials. The Construction Standard becomes effective January 20, 1987. For your information, attached is a ocnparisan of the old asbestos standard with the new Construction and General Industry Standards. The following is an explanation of the Construction Standard, where exposures exoood the 0.1 f/oc action level: 1. exposure MONITORING - Any construction or mainten ance operations where asbestos is present oould cause asbestos esqposure. in amass of the action level. (Monitoring is required whenever asbestos fibers may be released.) Ihe Engineering Estimating Sheet, aoocppanying Bill Strain's Dec. 22, 1986, memo, will be used by Industrial Hygiene, to determine whether monitoring will be necessary during removal/ repair. In addition, certain plants may be targeted for a followup audit, based cn information gained from that survey. 2. EMPLOYEE MTHFICATICN - If exposures exceed the action level, the OSHA standards require that affected employees be notified. Ihe notice obligation can be fulfilled by posting exposure results at an appropriate location or by sending employees individually-addressed letters with exposure results. Notice to employees should be iskied as soon as possible. Enclosed is a sample letter which can be constructed to meat the re quirement for employee notification. A record of the employee notification should bs retained in Personnel, with a copy sent to Plant and Oorporate Medical. 3. . SAMPLING AND MEASUREMENT - Ihe sampling and analytical prooadures in the new OSHA asbestos standards have been extensively modified to provide better precision and accuracy. If it is nscassary to monitor, Industrial Hygiene should be contacted, to Initiate these new procedures. 4. EMPLOYEE INFORMATION AND TRAINING - All employees who will be exposed above the action level must reoeive training prior to assignment to ths affected jcbe. Employees must have annual refresher training, thereafter, as long as they are exposed above the action level. Industrial Hygiene should be contacted, for the training aids to meet these requirements. TX TIMER RMC0086286 2 003602 Industrial Hygiene Bulletin #126 OSHA ASBESTOS STANDARD January 09, 1987 5. PERSONAL twi'jjLTIVE ECdPMEWT - Employees exposed at or above the action level Bust be provided with appropriate respiratory protection and protective clothing. Air-purifying respirators are required to have high efficiency filters. No single-use disposable respirators are allowed. 6. MEDICAL shbvetttanct: - The Construction Standard requires that enplcyees exposed above the PEL Bust be offered preplaoement and annual radical examina tions. Employees exposed above the action level far 30 ar Bare days per year Bust be offered a medical examination within 10 working days after the 30th day of exposure, and annually, thereafter. The General Industry Standard, however, requires that all employees exposed above the action level be offered praplaoment, annual, and termination medical examinations. a. PreDlaoanerfc - Preplaoement ex aminations refer to examinations prior to placement on jabs having asbestos exposure above the pertinent levels. Preplaoment examinations should not be confused with preplaoement physicals, which are given as part of the hiring process. The preplaoement examination offered to affected enplcyees must include a medical and work history; a couplets physical examination of all systems, with emphasis on the respiratory, cardio vascular, and digestive systems; a respira tory disease questionnaire, which appears in Appendix D, Part I; a chest x-ray (posterlor/anterior, 14" x 17"); a pul monary function test, including farced vital capacity (FVC) and farced expira tory volume at cna ssocnd (FEY 1.0); and any other additional tests deemed appro priate by the examining physician. Inter pretation and classification of chest x-rays Bust be performed by a Class B radiologist. b. Periodic Examination - The periodic medical examination must be offered to affected em ployees annually and Bust include all the items listed in the preplaoement examination. However, chest x-rays far periodic examinations should be scheduled in accordance with the following table: 3 TXTINER RMC0086287 003603 Industrial Hygiene Bulletin #126 OSHA ASBESTOS SIANDARD January 09/ 1987 jenev of Chest Roentgenograms Aoa of Btolovee vgarg since First Exposure 15 to 35 W 4? 45 0 to 10...................................... Every 5 years. Every 5 years. Every 5 years. 10+.............................................. Every 5 years. Every 2 years. Every 1 year. C. TtomHnation of Baalavmenfc Pv*wrln+-tcn - Termination examinations are not required far employees operating under the Construction Standard; however, those employees previously identified as having asbestos exposure aust be offered a termination of employment exami nation. This termination examination must include all items listed in the preplaoaoent examination as indicated in Item Na.N d. Record Keeping - A list of employees deter mined to have asbestos exposure at or above the action level must be maintained by Medical, in order to ensure adequate follow-up far medical surveillance. This list should be continually updated and a copy should be sent to Corporate Medical. e. aryg<e^nl8 written Opinion - When employees are given preplacement, periodic, or termination examinations in accordance with the OSHA Asbestos Standards, the examining physician must advise the employee about his findings and provide a written opinion regarding any medical oenditien relating to asbestos exposure. Removal/repalr projects which would be expected to produce asbestos exposures greater than the OSHA limit of 0.2 f/oc will require regulated areas, enclosures, engineering controls, work practioes, and personal protective equipment. It is obvious that working with asbestos-containing materials will be extremely oostly and compliance with the OSHA standard far removal/zepair projects quite extonsive and burdensome. Given the restrictions as outlined above, it will be preferable to utilize outside contractors to perform any work where the exposures may exceed 0.2 f/oc. Far those situations where an outside contractor is being used, Industrial Hygiene has developed a Contractor Asbestos Audit Form, to ensure the contractors' compliance with OSHA and guidelines. The farm should be used by the individual (i.e., the engineer) at the plant who is responsible far monitoring the contrac tor's progress. TX TINER RMC0086288 003604 Industrial Hygiene Bulletin #126 OSHA ASBESTOS STANDARD January 09, 1987 In order to ensure that all employees are Informed of the pres ence of asbestos in the workplace, all insulation (pipe, buUc, etc.) containing asbestos is to be labeled. The label shall contain the following information: CXXH3015 ASBESTOS FIEER AVOID aOXEDC DOST This label will be available from Corporate creative Services. (Order #R-342-58.) Labeling should be applied where confusion nay occur, such as close to valves or flanges and adjacent to changes in direction, branches, and where pipes pass through walls, floors, or ceilings. labeling is to be applied at the beginning and end of con tinuous pipe runs and every 75 feet where runs are longer. This Industrial Hygiene Bulletin incorporates the new C6HA Asbestos Standards into the Reynolds policy on asbestos and outlines the procedures that should be followed to implement the new OSHA standard. Attached is a copy of the OSHA standards on asbestos. If you have any question regarding this information or its application, please contact Industrial Hygiene. Attachments Distribution: EH-1 Division Engineers Plant Engineers Homer M. Cole Director Industrial Hygiene TX TINER RMC0086288 5 003605 Industrial Hygiene Bulletin #126 OSHA ASBESTOS STANDARD January 09, 1987 SAMPLE IEXTCR PCR EMPLOYEE NUilFlCATICN OF ASBESTOS ICNITOKQC RESULTS To: (Employee Name) (Plant) (Date) Cn (Date), we monitored you far asbestos exposure. Results of that evaluation indicate the following: less than 0.1 fiher/oc. Therefore, no OSHA limits were exceeded. Greater than 0.1 fiber/oc, but less than 0.2 fiber/oc, 8-hour time-weighted average. Therefore, the OSHA "action level" was exceeded. _______ Greater than 0.2 fiber/oc, 8-hour time-weighted average. Therefore, the OSHA Permissible Exposure Limit was exceeded. In keeping with our policy of protecting our employees' health, it should be noted that, during this project, you ware adequately protected from asbestos exposure by use of personal protective equipment (i.e. disposable protective clothing and a NIOSH-approved respirator). Should you need further information, feel free to contact me. Personnel Director TXTINER 6 RMC0086290 003606 TX TINER RMC0086291 003607 * | ll oKV& *Jf.t -3 St I1c ? 8 S. 8 .5 S .2 u >. a 5 - - o to i 9 -8 II 5 " 8J II 8 itKUf 1 *.1*2%* e - 85 S 2S 8v ?v fc.~ * * fc 8 . !.h slit 1*1 S Jl ry COMPARISON Of OSH* ASBESTOS SIANDARDS I i! !1 TX TIMER RMC0086202 003608 TXTINER RMC0086293 003609 Is 5 o O -- 5. -- --* u II 1 8- u. * *--s thij o * +* V 'lils li,is I wm 1 l # M li S _ i* ?5 !' * f! I! *8 X ** is s55 1 *1 1 ?! 8 -i s 32-K8 i 2 8 l! Mu i 1 s o 3 1 I e n I M s 1 8 i w U I i TX TIMER RMC0086294 003610 i * b s 1 g 8 u3 i ff i ^k --8 i s 1I * - w I COMPARISON Of OSHA ASBESTOS STANDARDS 8 8 Bl a a t 8. Hi S*i $W wil--_ VI |!i ill TX TIMER RMC0Q86285 003611 COMPARISON Of OSHA ASBESTOS STANDAKOS ..si! Iliill H?:|i4M?l li! i MilMl shrill iihh O yC TXTINER RMC0086296 003612 COMPARISON Of OSHA ASBESTOS STANDARDS Asbeetoe Medical curvei l lance guidetines (ran* Mandatory). sI a I i1 i j u a Ul iu a X * mbe IM A H iQ r 1 -5e t6 3t !! el; e& *1 ! s8 fi |l !5 ii Li =2 11| |i~1 e 1 S1 ~~i |- l a Ul ik X f TXTINER RMC0080297 003613