Document pBdx9DLmNqGwvVxJqLnYMwYVj

FILE NAME: DAP (DAP) DATE: 1983 Aug 12 DOC#: DAP102 DOCUMENT DESCRIPTION: Priddy DAP Talc Study Ife r %- f Th*Inamidai Conuntnlon ' ' ' .. OtCWo ' ` Oktilcci Of JohtV S Hyglmio . ! 246 N. HIpJ-i SI, Col, 0 . 132 August 12, 1983 EXHIBIT (&' Ir Mary Gerard ` Safety Director D.A.P. BS5 North Third Street Tipp City, Ohio 45371 Dear Ms, Gerard: , On May 31, June 1. end June 3 an industrial hygiene survey was conducted at the Dayton plant oy this writer with the assistance of Bob Prim, industrial Hygienist, and Dan Bentley, Engineer. Sampling at the Tipp City plant was completed July 26, 1983 and will be the subject of a separate report. Sampling and analytics!I methods used are discussed in .A ttachment 1. :Arilys8t.^ol^^ M |i^ p le i^ ^ liia lw ^ i 8sRig^m^i^wk^j>iidiltd'^h.-'.-ian~: credi t% 3 f ffii^ 5 S ^ t ta ^ & '^ D ! :have: been !x^mff^/iiccordingr'tt''. th area sampled. The dat f the survey is shown in the upper left-hand corner of these tobies. The noise data is shown in tables E-G, dat in upper right-hand corner. - . V,: ., ' . ' ' ; As can be seen from tnc attached tables, for the most prt, exposures were withiii acceptable limits established by- the agnais r'frhed: -Ct[a'chment: 2) These values represent exposures only under the conditions and production levels found during this survey and may vary considerably under other conditions, particularly in the winter months. Caution must also be used in applying respirable "nuisance dust" standards tosarne of the chemicals which are handled by the compounders for which little, if any, toxicological information is available. Of concern specifically arc the powdered preservatives and fungicides used, for which sampling methods are not : y el:available*'/:': f -i- : ' - } ' - ' ` l. D.A.P. Page Two Of more immediate 'concern is the lob report of approximately 1-3% Iremolitc asbestos in a bulk sample of talc (Code 22) which was in use during the survey. The respirable dust values cannot be used to project asbestos exposure levels. Asbestos monitoring must be conducted in accordance with the OSHA regulation 29 CFR ISL0.10D1, (Attachment 3). Due to the lack of local exhaust ventilation for compounding areas and due to the extreme health hazard posed by asbestos exposure, it is recommended that use of this particular tale: b e e lim in a te d .A s we understand the situation, ; . there are several., suppliers. oT Code"22, most -of'- Who. state'-Pi-m aterial safety data sheets that the tnlc is non-fibrous. According to our conversation during the Tipp City survey, the talc in question was supplied by VnndorbiJl. The inb reports an approximate i 25% accuracy in determining the asbestos content of a tale bulk sample by polarized light staining microscopy. The ehomisl slated that the manufacturers generally are not using the criteria of a 3:1 Icnglh-lodiamrter ratio in determining asbestos content, and thus their reports oT asbestos content are generally lower. If use of Ihc Vunderbilt tnlc continues, initial monitoring of employee exposure is required by the current OSUA asbestos standard. The Director of the Occupational Safety and Health Administration recently described the 2.0 fibers per cubic centimeter permissible exposure limit (t'KlJ ns "insufficient to prevent cflneer, nt least in some cases." lie projected that revision of the PHI. and issuance of n final rule should be completed later this year (1983). . .. . .In the. interim and . until .initial monitqnng- results urn. .available,- i t is recommended D in t, in n re ris / where .the asbestos-containing '.tnlc-.'is in//use. employee use of respirators approved for protection against toxic dust including asbcslos (not the 3.M 8710) become mandatory and (hat strict housekeeping practices for dust control be Implemented. Dry sweeping of dust containing asbestos is prohibited. Clean-up methods include wot methods which prevent reintroinmenl of the dust after the water hos evaporated nr high-cfficicncy filtered- vacuum systems. (Attachment f for .illustration purposes only) . It is also recommended that since asbestos had been used to a much larger extent in the past, an effort be made to identify those employees who incurred exposure nnd to place them in a medical surveillance program. Such a program would include an annual or semi-annual physical examination, pulmonary function testing and chest X-rays. Implementation of such a progrnnt may lead to curly detection, and thus' early treatm ent, for asbestos-rein led disease, perhaps reducing the suffering nnd costs now associated with asbestosis and cancer. Yon may wish to contact the.Kettering Lob of. the University of Cincinnati College, of Medicine, the (tit. Sirinf School of .Medicine in New York, or the National Institute for Occupational Safety nnd Health (NIOS1I) In ' Cincinnati. Ohio, for ' information concerning a medical surveillance program. D.A.P. Page Three The following paragraphs regarding asbestos have been summarized from several resources. Much additional information is-available-through contacting our Resource Center in Columbus, Ohio, a l l . (800) 232-3045. . . : . ` Asbestos fibers find entry into ,the body by inhalation and ingestion* The fibers are retained in the body tissues throughout the lifetime of the host, even long after cessation of exposure,- Fibers may.migrate, to other organs following retention in. the lung:. .: Asbestosls and certain.-,malignancies are -related to "VV;T, ....... ' ' Asbestosis is a progressive restrictive pulmonary fibrosis associated with inhalation of asbestos fibers. Malignancies related to the inhalation and possibly ingestion of asbestos fibers by epidemiological studies include carcinomas of the lung, mesotheliomas of the pleurs and peritoneum, and noplasmes of other sites. Asbestos has a synergistic effect with cigarette smoking in producing CBrcinoma of the lung. Asbestos workers who arc smokers have over 30 times the risk of non-exposed non-smokers of contracting lung cancer. Although respirator use is now considered voluntary in the compounding area, a physical exam to determine if an employee is capable of wearing a respirator is standard practice. Such a determination is required by the 1980 ANSI standard Z-88.2 paragraph 3.5.3 ond is referenced Irt the OSHA standard 29 CFK 1910.13-1. In regard to your question on OSHA enforcement activity on this m atter, the Industrial Hygiene Department of the OSHA Cincinnati Area Office was c-oniacted b u t; the details (company nam e,exposure levels) - were not . discuraed;;iv -Mr:;;b ic k :Gilgr&Nstat ed^ th e^re^irem en tfio rv ip h ^sicai^^ generally cited without documentation of overexpesures,'however the situation would be evaluated on a cose^-by-case basis with factors such as working-force age, smoking history, history of cardiovascular disease, heal stress, and past exposure to toxic chemicals considered. - / . . Regardless o f Federal policy in; enforcing .or not-cniprcingithis standard;, the determination by a physician that an employee should not suffer additional cardiovascular or pulmonary stress or experience other physical problems before he or she is given a respirator to wear is important in protecting worker health and possibly in reducing future occupational disease claims. Such an exam also provides an excellent opportunity to review selection, fitting, cleaning and storage practices included in a respiratory protection program. The nature of some of the materials handled in the Dayton plant presents the opportunity for th e ; development of dermatitis. It was. ..observed that cleaning of. Hie .Dutyl-fiex line was .'conducted .byi.empioycs.' wlu1 were not wearing protective gloves. Solvents cari dfat the skin causing dryness.- irritation and cracking which can be complicated by infection. Additionally, some solvents enter the bloodstream through the skin, the skin acting as a route of exposure. D.A.P. Page Four . Norval Phillips, a compounder, complained o f a "poison-ivy" type rash after using Napocide N-40-D. According to. the material safety data sheet this materia!, is a skin irritan t and;.."causes an increased tendency to become allergic." Apparently, the manufacturer ijs''sta lin g the fungicide-is a sensitizer. We observed that Norval used disposable-clothing, a dust mask, and gloves when adding Napocide to the batch.. 'Such strict measures to prevent skin contact should be implemented among all'compounders who handle Napocide. and those _ _ _________ ... ___________ . 'the-. classification of dusts as nuisance or "inert" can be misleading and a more correct implication would be th at such dusts do not cause pulmonary fibrosis, physical Impairment or disease." Inert dusts do not produce fibrosis, but Increased airway resistance can result from excessive mucous production stimulated by the deposition of inert particles on the surface of the upper airways. Although exposure to such dust may not be as potent a factor in causing chronic bronchitis and emphysema as cigarette smoke, there is some evidence according to Patty that "occupational dust" may at least contribute to chronic bronchitis. The ability of the Napocide to cause allergic reactions illustrates our introductory cautionary statem ent concerning the classification of such ma terials in their dry form as "nuisance dust." In general, fungicides and preservatives must conluin one or more biologically active ingredients in order to be effective. ' '. The below for ease o f reference; -The lab could not provide sampling method information for any-bi'-these: : ' Code 187 Dowocil 75 : - 67.5% l-(3 chloroaiiyl)-3,5,7-triaza- . . . . ' 1-azoniondomentane chloride Code 774 ' Troysiin 174 : 2-{(bydroxy ethyl) amino],ethanol Code C-795 Nuo Sept 95 - 24.5% S-hydroxy methoxy methyl-1aza-3,7-dioxabicyclo (3.3.0) octane 17.7% 5-hydroxy methyl-l-nza-3,7dioxabicyclo (3.3.0) octane 7.8% ' 5-hydroxypoly {methylene oxy . (74.% C2 21% 03, 4% C4. 1%: C5)] m ethyi-l-aza-3,7-, dioxabicyelb (3.3.0) octane Code Napocide N-40-D - 40.4% tetrachloroisophthalanltrile The m aterial'safety data 'sheets provided little toxicological information for these chemicals, but all were listed as eye, skin, or respiratory irritants. Until information is available to the contrary, it should be assumed that inhalation of or skin contact with these materials may elicit a negative response in humans. Use of adequate protective equipment including protective, clothing and gloves, . respirators, and goggles is advised. . . VTh& noise levels'-were for:; the m ost-part below art. B-hour time-weighted !averagero-85 dBA dtuung.the survey date.^T he exception;was on thcP anel Line where exposures were bdnrine, 86dB'andB4 d L A fo rth e operatoh'ahd crew.." chief, respectively. Employees In this area should be included in a hearing conservation program as outlined in Attachment 5. Control of compressed air noise from the straight tubing used to move ports along this packaging line might reduce employee exposure to a point where a hearing conservation program is not needed in this area. A longer sample is needed for the Butyl-flex packaging line. Due to resource limitations, we cannot conduct an annua! industrial hygiene survey; however, we will try to assist you in monitoring specific processes as requested. Our three-day survey did not enable us to sample several operations which are of interest. One of these is the premix compounding for Butyl-flex in which the "rubber hog" is used. The noise and dust from this operation was the subject of more than one complaint by employees. The operation wbs scheduled for June 3, 1383, but was cancelled when an employee did not report for the-firsi . s h u i . ^ ; ; ;.......... . ^ .. ......... . ......................... In addition to the "rubber hog" other operations/^ for 'Twhich'ismpling is recommended include the following: . . ' ' ' 1. ' Cabosil 'tran sfer in small Flexiseal. Room - dust : 2. Piitty making of pipe joint and soil pipe cement - dust '. . v : -.'S.Y. : 3. Ceramic tile adhesive - ammonia 4. Compounding of products which contain Code SB6 for free crystalline silica. 5. Compounding of products which contain Code B03 (PVC acetate emulsion) - formaldehyde. A grab sample taken with a Lion Formaldehyde Meter showed 17 ppm formaldehyde present in the head space of a dmm of Code ; ' 803 immediately after, the.cover of the drum was lifted. The meter reading ' ' may have been falsely high due to interferences from alcohols; however, it does indicate employee exposure "monitoring is warranted. V' ' . D.A.P. Page Six 6. Six-stem packaging line in General Compounding for full shift noise exposure. This operation only, ran a half day during our survey, f: 7` FillinS UUwcans, which are reported to be noisier than the paper-labeled . . . cans- ..... . ; .-. - ' . fcW u , I. packaging line.' A 135-minute sample ` .... " ... 9' S 1.U?8L,'r eP*y containing Cellosolve acetate {compounded In Tipn ' v-ity) See Attachment 6. ^ 10. Duratite 6000 compounding - toluene 11. Because past sample results in General Compounding and other mixing areas were for total dust, it would be helpful to obtain additional total dust samples Tor comparison. However, given the choice between obtaining total dust samples end respirable dust samples in the limited time available, we chose to sample for respirable dust since this more accurately represents the amount of dust which enters the deeper portions of the lung. The filter contained in the 10mm nylon cyclone used is generally considered to capture particles of less than 10 microns in diameter which rrc defined as respirable. if, . I I A ine large..variation, in. th e .total, dust sample 'and'respirabie ausLsample.obtained, for; the pigment weigher; 80.0 mg/M3 : vs, 1.0 mg/MJ , respectively. The total dust sample may have been tam p ered ' ^ ' ^ with, but the cyclone sample for respirable dust appeared normal. The total dust and respirable dust sample results for the speckling compounder are much closer in value; 2.2 mg/M and l.Tmg'/M , respectively. , Please contaet our-Dayton District: Ornce .{513) 898-320s if you need further assistance or have questions concerning this report. ' It was a pleasure to work with you and other D.A.P. employees. Respectfully submitted. MP:gjb Marilyn Priddy Cr IndustrioJ Hygienist d.a.p. Page Seven Enclosures: Attachment 1 - Sampling and A naiyuW Methods" - . . Attachment 2 - "Applicable Occupational Health Standards" ! Attachment 3 - 29 CFR 1910.1001 - OSHA Asbestos Std. ! Attachment 4 - Vendor literature on toxic dust vacuum sweepers Attachment S - Siimmafy'or Hearing1Conservation Std^- ' '" ' -1 Attachment 6 NIOSH Current InteUigence Bulletin #39. Table A - General Compounding Table B - Room 20S Table C - Panel Room Table D Table E Table F Table G - Flexiseal Room - Noise Exposures 5-31-83 - Noise Exposures 6-3-83 - Grab Samples - Noise . Attachment. 1 . "Sampling and Analytical Methods" Dust - ' . ' . y 1 - ;v . Respirable, dust samples were collected oh tared PVC filters contained in 10mm nylon cyclones. The'cyclone 'was placed, in the breathing zone of the.; ; , worker by,attaching it to his or her collar.' Tygon tubing connected the cyclone.' The cyclone separates the dust Into the respirable portion (particles with an aerodynamic diameter less than 10 microns), captured by the filter and the nonrespirnble portion (particles with an aerodynamic diameter greater than 10 microns), which is collected in the grit pot and discarded. In general, particles larger than 111mm are trapped in the nasal passages, throat, larynx, and bronchi from which they are expectorated or swallowed. Particles less than 10mm can be deposited in the terminal recesses of the lungs which allows interaction with delicate pulmonary tissues. Total dust samples were collected on tered PVC filters with Model G MSA pumps for power supply. Doth types of samples were submitted to on accredited industrial hygiene laboratory where they were analyzed for weight gain. Bulk samples were analyzed far silica content with X-ray diffraction and for asbestos content with polarized light staining microscopy. Less than 1% -aunriz.wss found, in the bulks submitted. Asbestos content of the tele is Breathing-zone samples were collected using charcoal tubes and,. Sipin , . pumps; and,;:3MiOiganic-Vflpor Mbnitorst ;,.The pumps were, calibrated.at. n'rate to ' , allow a morning 'arid'aftcrr.ocn sam ple to-, be obtained (70-7.5;"Cc/min).f.Analysfc=i>. ' was by gas chromatography. ' " '*" The results reported "as hexane" are used by the lab to report con centrations of mixed petroleum solvent vapors other than those specifically requested. For example, mineral spirits, VM4P napthc and similar materials may contain 15-50 different components. A mg/M3 value can be obtained for mineral spirits or VM&P naptha when a bulk Is submitted for analysis and no other specific chemicals are requested. But, the separation identification of the individual,'components cannoL be determined completely.... In, most cases, specific chemicals such ns toluene 'or imlmne were; a l ^ of interest. w : the/lBb was;: t. ; .. requested to report the bdimce i|!as hexane*' rather ' than .in ' mg/M3." Attachment/ I (Continued) Noise Soum3 pressure (noise) levels w ero 'ev aiu ated /u sin g 'Q u est dosimeters calibrated before and after .use^ -^Theser.'dosimeters`are;personal sampling monitors that measure the sound pressure which reaches the car. .`Because the dosimeters centinuelly:integrate; during the entire ^testing' period, the result, represents.: the worker's ayerBge^exposureifpr:Ja;3tandart:,lwprkday.';Withj the5e,; devic^sK ort 1hteiM ';n d i s e 'O ^ O ^ t K ^ i ^ ^ i t U e - '':eflteF7i(i'`*tJ)e- overoll average. The range of error for'dosim eters :is 'approximately plus or minus 2 decibels. This means that sound pressure levels may actually be slightly higher or lower than the figure reported." Dosimeters used were Quest, Model 7B and Dupont, Model MK-1. - .: The columns in Table E and F labeled "Calculated by dosimeter" represent the time-weighted average calculated for the time the dosimeter was worn by the employee. The columns labeled "8-hr. TWA" represent the exposure calculated by assuming zero exposure for the time the dosimeter was not worn - lunch and time at beginning and ending of shift. The 8-hour TWA was not calculated in a few instances where only a half day sample was obtained. Instantaneous sound pressure levels were evaluated with a General Radio 1988 Precision Sound Level Meter and Analyzer calibrated before and after use. Instantaneous measurements are made to confirm tests made with dosimeters and to map areas where workers may be overexposed to noise,(See Table G) Attachment 2 "Applicable Occupational Health Standards" Standards and guidelines from three different health organizations Slave been displayed in the Tables. Probably the most familinr of these is the Occupational Safety and Health Administration (OSHA) -- the promulgator and enforcement agency of occupational health laws. In it 's 1970 inception OSHA adopted the threshold limit values (TLVs) established- by ipe American Con ference of Governm ont al Industrial Hygignists (ACGIH). forning-, the - foundat ion of their 'occupational x p t^ e ~ f g te fi6ris.!: OSIA. however,' unlike'the' ACGIH does not have the immediate flexibility to change or update a particular standard without first submitting it for congressional approval or the issuance of an emergency temporary standard. Thus, only a hand full of compliance standards have altered since OSHA's inception (i.n. the standards for lead, vinyl chloride, noise, etc.). On the other hand, the ACGIH reviews annually their TLVs in light of current research developments, epidemiological studies, clinical evidence, and laboratory experiments making appropriate changes when a guideline appears deficient. Furthermore, the ACGIH qualifies their guidelines in slating that "Threshold Limit Values refer to airborne concentrations of substances and represent conditions under which it is t>elloved that nearly all workers may be repeatedly exposed day after day wihoul adverse effect. Because of wide variations in individual suscepti bility, however, a small percentage of workers may experience discomfort from some substances at concentrations at or below the threshold limit; a smaller percentage may be affected more, seriously.. . , - , by aggravation o f pffr-existirig^condftion o r;by development of "an ; r . occupational'illness. Th TLV-TWA shoiiid be used as guides in the control of health hazards and should not be used as fine lines between safe and dangerous concentrations."!. The National Jnstitulc for Occupationni Safety and Health or NIOSHTn turn is OSHA's supporting research organization. Under the J 970 OSIMct, NIOSH is responsible for identifying occupational safety and health hazards, for de termining methods to control them, and for recommending Federal standards to limit the hazards. The NIOSH proposed standards, based on much oT the same information as the ACGIH TLVs, ore standards to be considered by OSHA for future promulgation in providing optimum protection for workers. Attachment S "Summary of Hearing Conservation Standard" Monitoring . . The hearing conservation amendment requires employers to monitor noise exposure levels in a m anner.that will accurately identify employees who are exposed to noise at or above 85 decibels (dBA) averaged over, eight working hours, called an 8-hour time-weighted uvernge (TWA). The exposure measurement must include all noise .within.an 80 dBA to 130 dBA range and must be taken during a typical-work situation. ; - ' . \ . ...Under, ;Thei.Tevised:;:Bmehdment mbiiitoring 'procedures "and~they the *reSultsi of^ the exposure monitoring of their workplace. The method used to notify employees is left to the descretion of the employers. Audiometrie Testing Audiometrie testing not only monitors the acuity of an employee's hearing over lime, but also provides an opportunity for employers to educate employees about hearing and the need to protect it. The important elements of an audiometrie testing program include baseline audiograms, annual audiograms, training, and follow-up procedures. Audiometrie testing must be made available to all employees who have average exposure levels over an 8-hour period of 85 dBA. And the audiometrie testing program follow-up should indicate whether hearing loss is being prevented by the employer's hearing conservation program. A professional audiologist, and otolaryngologist, or a physician must be responsible for the program. Both professionals end trained technicians may eonduct audiometrie testing. A. Basel ine Audiograma ^ The baseline audiogram: is the reference, against which future . audiograms are compared.. Baseline audiograms- must be provided ...: within B months of an employee's first exposure a t or above an 8-hour TtVA of 85 dBA. Where emplcyers:are;,using mobile test.vans to obtain audiograms, baseline audiograms must be completed within one'year after an employee's first exposure. If delayed for one year, Ihe exposed employees must be issued and fitted with hearing protectors to be worn until the baseline audiogram is obtained. B. Annual Audiograms 'r`- mnual audiogram must be conducted within one year of the . base! Annual audiograms must be,routinely compared to baseline : '> audiograms to de^rm ine - whether.The .audiogram is- ace urate an d ;to . determine whether.tbe empibyeVhas :lost: hearing-ability (that is, i M : standard threshold. shift (STS) has occurred.)- ...STS is defined in the amendment as an average sh ift'in either e a r1of 10 dBA or more at 2DD0. 3000. and 4000 Hz. . . v. ; ' ' Attachment 5 (Continued) til. Audiogram Evaluation If an STS Is identified, employees must be fitted or refitted with adequate hearing protectors, shown how to use them, and required to wear them. Employees must he notified within 21 days from the lime the determination is made that their audiogram results showed an STS. If subsequent audiomelric tests show that the STS Is not persistent, employees whose exposure to noise less than a TWA of 9D dBA may discontinue the wearing of hearing, protectors, . v IV. Hearing Protectors " . ' "" ................. r , Hearing protectors must be available to all workers exposed to 8-hour TWA notse levels of 85 dBA or more. This requirement will ensure that employees have access to protectors before they experience a loss in hearing. Hearing protectors must be warn by: 1) employees for any period exceeding S months from the time they are first exposed to B-hour TWA of 85 dBA or above until they receive their baseline audiograms in situations whore baseline audiograms are delayed because of mobile test van con venience; 2) employees who have incurred an STS since these workers hove demonstrated that they are susceptible to noise; and 3) employees exposed over the permissible exposure level (PEL), and 8-hour TWA of 90 dBA or above. Hearing protectors must adequately reduce the severity of the noise level for each employee's work environment. If workplace noise levels increase, employees must be given more effective hearing p'oteeiors. The .protector must reduce em ploytoexp^ures to a l l east 90..dBA and to 85 ' dfiAwhbrv cfSTS ;hds`alfepdy.-dcciifid,-itr:^thei.wdrker.'s hearing must be shown how to use and care for th eir'p ro tecto rs and must be supervised an the job to ensure that they continue to wear them correctly. V. Training . . . ' :. Employee training Is very important. When workers understand the ' reasons for the hearing conservation program's requirements and the need to protect their hearing, they will be better motivated to participate actively in the program. Employees exposed to TWA's of 83 dBA and above must be trained at least annually in the effects o f noise, the purpose, advantages, and disadvantages of various types of hearing protectors; the selection, fitting and core of protectors; and the purpose and procedures of audiometric testing. VI. Recordkeeping - .. ...... . .. . . Noise exposure measurement records must be kept for 2 years. Records ;of "audiometric test results -m ust. be ' maintained . for the duration of employment of ,,iie affected employee.-; Audlometric' test records must ..:. ..include 'th e .name nnd job class! Heation,of the.employee, the date, the examiner's name, the date of acoustic or exhaustive calibration, measure-, ments o f the background sound pressure levels in. audiometric test rooms, and the employee's most recent noise.exposure measurement.. g .-J-'* :/ J k A J - .- .r PuVtQlL- Jnp 1. 19B3 TABLE A ' ' ; NAME/SITE SAMPLED . . POSITION/ . OPERATION-'- . . CONTAMINANT TWA ' B-hr.` 'fo r TWA tim e Sam pled ____ J TIME. CONCENTRATION OSHA SAMPLED DETERMINED STANDARD in mg/M3 : 7- in mg/ill3 TLV-TW A 1 NIOSH PROPOSAL in mg/M3. ACGIH STANDARD in mg/M3 ipaekling .;,- .7 .77. Cyclone: 401 ' / 1.7 : 1.4 .General Compounding Compounder". _ . Respirable Dust ' . y - 5-Y . ' 1:. 5 . ;-; ' ..v 33 Glaze PVC filter 374 7.4 . 5.7 15 General Compounding Compounder ' Total Dust - . 10 Contains Taic, Code 22 . -v; ' * Resample and use asb slos standard: Bulk Sample Code 22, Taic Asbestos - TTemolite 1-3% 2.0 f/cc 0.1 f/ce (under reviev ) 2.0 f/oc ` ' - `H!'-" ' r- - mg/MJ = Milligrams per cubic meler oi alr - . . . . . S^ *-pprri'% :H * Parts per million of air' #. ;7 . ' " T ; OSHA ' = Occupational Safely and Health Administration ' NIOSH ; Nalional Insll tula ol Occupational Safely & Health I f o ; A C G IH : American Conference oi Governmental Industrial Hygienists rJhV' ` ' . . . .....v: . . . ' .. . SHIH-Wl . - . . vT\ TLv . ;. Threshold Limit-Value ' ' TWA Time Weighted Avrg ............ or NAS. .; . No Applicable Standard -v ..: f/cc - fibers > S^m /cubic centimeter : -.y;... ' ' P. A.P. - Dayton -7- - -: rugu. i m iuil- fi June 1, 1983 ________________________________________________ ___ .___ ._______ TWAt P-hr. for TWA tim e 1 _________ . -Sampled______________ .___ n am e/s it e 3AMPIEO POSITION/ OPERATION CONTAMINANT TIME CONCENTRATION OSHA SAMPLED DETERMINED STANDARD in ppm in ppm General KwJk Seal OVM: 440 < 1.0 < 1.0 150 Compounder . Butyl aeei- .e Compounding TLV - TWA 1 NIOSH proposal in ppm ACGIH standard in ppm 15D % -.S; AVr - : Cyclone: 393 0.14 0.11 in mg/M3 General Compounding Pigment Weigher PVC filter; Total Dust: 353 108.B SO.O 15 ' 3 '. Ftmpje OBPeared to |iflve._been lampered., wilh_ 3 5 . mg/M* "ppm ' OSHA NIOSH ACGIH ; Mlllierams par,cubic meler of air. ... ... "... Parts per million of air ' : ' ': 7 v Occupational Safely and Heallh Administration Nallonol Institute cl Occupational Gaiety & Heallh * American Conference o'Gr-fornmen'al induilrial Hygienists .. TLV.: i . - Threshold lim it Value . iivV:-TM'-::7.1V'Time.Vyaighied-vera5fe7- o r N.A.S. Nd Applicable Standard .-i. . .V'-r- & .LWUV - Dayton .iTun&..a, 1983 NAME/SITE SAMPLED General Compounding TABLE A TWA for -ttem - fl-hr. TWA _L_ TLV - TWA POSITION/ o pe r a t io n CONTAMINANT TIME CONCENTRATION OSHA SAMPLED DETERMINED STANDARD in mg/M3 in mg/M3 NIOSH PROPOSAL in mg/M3 ACGIH STANDARD in mg/M3 . '.^"'3 -V-," ..-rr _- '.o-r-.' Pigment Weigher Cyclone: 352 1.3 . Respirable Dust 1.0 5 -- 5 * Handled Code 22 which was found t contain 1-3% tremo ite (asbest :s), should be res empled. Genera1 Compounding Speckling Compounder `- i batches PVC filter. Total Dust in mg/M3 in mg/M3 in mg/M3 in mg/M3 370 2.S 2.2 15 -- 10 mg/M1 ppm OSHA NIOSH ACGIH Milligrams per cubic melar ol air Paris per million o( sir Occupational Salaty and Health Adminiclralfon * National Institute of Occupational Safely & Health - American Conference of Governmental Industrial Hygienics . TLV TWA o r N.A.S. - Threshold Limit Value - Time Weighted Average No Applicable Standard ~ ` ...--.-j--: "--- ' . U.A.P. - linvton -JuoaJL,-13g3-_ ........... '____ __________.__ __________________ - - NAM E/SITE POSITION/ . SAMPLED OPERATION CONTAMINANT TABLE B TWA B-hr. for TWA tim e i ________ -i--sampled ._____________ :___ TIME CONCENTRATION OSHA SAMPLED DETERMINED STANDARD In ppm in ppm ci";r^fT-Roomr' 205" ' Butyl- fleit tV -'-'Com]under4vi- ehjffcoal Tuija: ' VM&P naptha "as hexane" .... : 204.';.; |Tpkn&iMily); 26 Benzene < 0.01 10 TLV - TWA 1 . . _ NIOSH ACGIH PROPOSAL STANDARD in ppm m ppm 10. A2 OVM: Mineral spirits 4 465 31 30 VM&P naptha, !'as hexane" Benzene <0.01 <0.01 10 60 10, A2 Buik Sample ' Contains Code 22, Tale . Code 22,. Talc ; .SrXSiSS2.. .... Respirable' Dust ' Asbestos-tre m o lile .' 426 - in mg/M3 in mg/M3 in m g/M 3 in mg/M3 ^2S ^ ^ '' . f22V ~ ' 5 ''T'--- !;T ' ** ResampU and use asfcestas standard 1-3% tremolite. 2.0 f/c c Q-L.Uss _ 2rQ_j/fl,. 'under review) mg/M1 ppm OSHA NIOSH ACGIH = Milligrams per cubic malBr of air = Parts per million of air ' = Occupational Safety end Health Administration > National Institute of Occupational Safely & Health ~ American Conference of Governmental Industrial Hygienists -- or TLV TWA N.A.S. A2 (Yro - Threshold Limit Value - Time Weighted Average No Applicable Standard - Suspect carcinogen - fibers > 5 ttm/cubic centim eter SHIH-001 .A.P. - Davton June 3. 1983 N A M E/SIT E SAMPLED ' .T"*--%* - - . , ` - Room'205 " POSITION/ ; OPERATION Tops' " - ' Compdunder " ; - 2 batches TABLE B W fife time CONTAMINANT TIM E SAMPLED sampled C O N C EN T R A T IO N DETERM INED in mg/M3 Cyclone:. . .Respirable Dust 397'' 0.37 0.31 OSHA STANDARD in mg/M3 5 ' TLV - TWA NIOSH PHOPOSAL in mg/M3 ACG IH .1 STANDARD in mg/M3 ' - ' 15 CVM: Benzene "as hexane" in ppm in ppm 433 <0.01 <0.01 10 6.6 6.0 - in ppm -- -- in ppm . 10. A2 -- - Room 205 MRM Line Surface Degiosser OVM; Benzene 468 <0.01 < 0.01 10 rest "as hexane" 18 18 10. A2 -- -- " ... , mgfM' ppm OSHA NIOSH ACG'H = Milligrams per cubic meler of air . , = Paris p er million ol air ' ' = Occupational Salely and Heallh Acfmlnlslrallon = National inslllule of Occupational Safety & Health = American Conference ol Governmental Industrial Hygienists 5 HIH-0C1 TLV TWA or N.A.S, A2 - Threshold Limit Value - Time Weighted Average No Applicable Elandard - Suspect Carcinogen " Tjrr- nt Jl f D.A.P. - Dayloti . NAME/StTE SAMPLED Room 205 POSITION/ ' o pera tio n TWA 8-hr. for TWA __ lim e ___ l__________ TLV - TWA ......... ) ' ... :______ semnlprl________ __________________ ... . ...... . : TIME CONCENTRATION OSHA COVTAMINAKT.;...; SAMPLED DETERMINED s t a n d a r d NIOSM ACGIH PROPOSAL STANDARD '' MRM Line-^j'^--i < Surface : Deglosser Toluene: Acetone.; -- 796 gallons -- 3600 quarts -- fan not on Benzene:' . Butyl acetate Mineral spirits, "as hexane" in ppm 394 10.4 8.5 in ppm 500 _EE2L in ppm OVM: Butyl 447 0.14 0,13 50 25 ' -- _ :;v !... -r " tng/U* ppm OSHA HI OSH ACGIH - Milligrams per cubic meter of air :; ' ~ Par!* per million oi air "- : ' ' * Occupational Salely and Health Administration ; . . * Nalionaflnstitute ol Occupational Safely S Heallh - American Conference o! Governmental Industrial Hygienists T" TLV TWA -- o r N.A.S. A2 - T hreshold Limit Value - Time W eighted Average No Applicnhle Standard - Suspect Carcinogen U.A.I*. - Uli Violi June 3' 1983 NAME/SITE SAMPLED POSITION/ OPERATION - Boom 205 . MRM Line - . 1 ' Surface - 1 Deglosser * *& ....i. . CONTAMINANT Charcoal Tube: Toluene \ Acetone Benzene > Butyl acetate "as hexane" TABLE B TIME SAMPLED TWA for time samoled B-hr. TWA CONCENTRATION DETERMINED ( OSHA standard in ppm [ in ppm 332 4.1 - 3.4 10.1 8.3 < 0.01 < 0.01 < 1.0 <1.0 3.1 7.5 . 200 1000 10 150 TLV - TWA 1 NIOSH PROPOSAL in ppm . . 300246 -- -- -- ACGIH STANDARD in ppm 1 G0 750 10, A2 150 -- OVM: Isopropanol 447 5.8 5.4 400 400 .- - - . mg/M* ppm OSHA NIOSH ACGIH = Milligrams per cubic mBler ol air = Paris per million of air 1 = Occupaliona! Safely and Health Administration = National Institute of Occupaliona! Safely & Health = American Conference of Governmenlal Induslrial Hygianlsts shih-oji ............, ___________ TLV TWA -- or N.A.S. A2 - Threshold Limit Value - Time Weighted Average No Applicable Standard - Suspect Carcinogen D.A.P. - Dayton June 3 . 19B3 NAME/S1TE SAMPLED - Room^ 205. * Area Sample POSITION/ OPERATION CONTAMINANT TABLE B TIME SAMPLED TWA for time B-hr. TWA sampled CONCENTRATION DETERMINED TLV - TWA OSHA .. NtOSH ACGIH STANDARD PROPOSAL STANDARD tn ppm in ppm w ppm in ppm ,,Butyl-flex. Line,? OVM: .... .... . cleaning, using" '* Benzene 300 <o.or. <0.01 io Mineral Spirits rest "as hexane" 25 IS' 10.-A 2 SO Charcoal Tube: Benzene 209 0.01 <0.01 10 rest "as hexane" 33 10. A2 60 Employee who wa; being sampled did not return from lune h, so sample left in work a ea for an area sample. m grM ' ppm OSHA NIOSH Cl 'l I - Milligrams per cubre m elero ! air Paris per million of air ' = Occupational Salely and Health Administration = National Instilute ol Occupational Safety &Health - Amerirnn Conference ol Governmental Industrial Hygienists TLV TWA or NA.S. A2 - Threshold Limn Value - Time Weighted Average No Applicable Standard - Suspect Carcinogen D.A.P. - Dayton June V. 1963 NAME/SITE SAMPLED - Panel Room - Strothers - Wells Mixer POSITION/ OPERATION Duratile 4000 Compounder TABLE C - - . CONTAMINANT TWA ' for 8-hrTWA tim e sa moled TIME CONCENTRATION SAMPLED DETERMINED OSHA STANDARD in ppm in ppm .Charcoal.tube:,- V : > Toluene - ' 420 7.0 ' -5.0 200 n-hexone 29.0 25.1 500 Benzene <0.01 <0.01 10 Lactol spirits 5.0 4.3 "as hexane" TLV - TWA NIOSH PROPOSAL in ppm ACGIH STANDARD in ppm 100 100 100 50 10, A2 60 OVM: i Isopropanol 463 5.0 5.6 400 400 4DD Cyclone: in mg/M3 in mg/M3 in mg/M3 in mg/M3 Respirable Dust 421 0.30 0.26 5 5 " -- - - . ;;v . V . r-.-vi- : ; .Hr ? 5S ! 5 HIH-001 u.'a. p . - Dayion i'iige ^ ol tupfe u June 1, 1983 NAME/SITE POSITION/ ^ SAMPLED__________OPERATION ______ CONTAMINANT TABLE D TIME SAMPLED TWA for time 8-hr. TWA sam p led CONCENTRATION DETERMINED f TLV-TWA_______ 1 ____________________________________ ____ OSHA NfOSH ACGIH STANDARD PROPOSAL STANDARD Clarence BiiDrey . . Construction r -iHexiseal-.Kciom- Adhesive " Compounder Charcoal-Tube: ::W :rtTiexane: . ' V Cyclohexane .. Benzene n-heptane in ppm . m ppm in ppm in ppm 424 19.7 17.4 500 : 3:8- - 3:3- - -300' < 0.01 < 0.01 10 <1.0 < 1.0 500 TOO 50 . - : 30D --* 10, A2 85 400 OVM: Ethanol 461 <1.0 <1.0 1000 1000 in mg/M3 in mg/M3 in mg/M3 in mg/M3 Cyclone: Respirable Dust 420 0.28 0.25 5 5 :r=-V-: - mg-'M* pom OSHA NIOSH ACGIH = Milligrams per cubic meler of air- . = Paris per million of arr ' = Occupalional Safely and Health Administration = National Institute of Occupational Safely & Healih - American Conference o( Governmental Indusliial Hygienists SH1H-001 - 1 ' ' _ _ _ _____ I TLV fWA or N A.S. A2 - Threshold Limit Viiiiie - Time Weighted Average No Applicable Standard - Suspect Carcinogen -' V U.A.P. - Dayton 1JgL' i U1 JHIU i) June 3. I9B3 NAME/SITE POSITION/ CONTAMINANT TABLE D TIME SAMPLED TWA fortime s-hr. TWA sampled CONCENTRATION DETERMINED OSHA in ppm in ppm a - Flexiseaj Room Sehwerdel Filler : - Construction ' Adhesive ' '= - 798 quarts Charcoal Tube: . . nrhexahe 181 * V Benzene1- ' 'p.m.: cm]y) . Cyclohexane n- heptane rest "as hexane" li.i 0.01" 1.3 1.0 1.0 . V- -- . 500 - 10 300 500 -- TLV - TWA NIOSH ACGIH in ppm in ppm 100 50 r J 0(.-A2 : 300 ' 85 400 OVM: n-hexane 438 25 23 500 100 50 * Pump malfunclior for a.m. charcoal tube sample -- ` * - , ' ' ` - | - . ' ..i r' 'r - W .- .f mg/M1 ppm OSHA NIOSH ACGIH = Milligrams per cubic meler ol efr . = Paris per million oi air = Occupational Soicly and Health Adminislrallon - National Instilule ol Occupational Safety & Health = American Conference ol Governmental Industrial Hypiwiisis ....... ' TLV ' " TWA -- OT N.A.S. A2 ~ th resh o ld Limit Value - Time Weighted Average No Applicable Standard - Suspect Carcinogen SHIH-0 I Etor n o is e le v e l surveys Oonpany lo c a tio n D.A.P. - Dayton Surveyor H. Priddy & B. P rim " ' ' TABLE E Efete o f Survey Hay 31, 1983 Model DuPont MK-1 ~ C alibrated by d o sim e te r 8 h r TOA M onitor S e r i a l Work tktrber 5CSB Name'of Fnploye^ C alibration . Reading Time S tert/F in ish on Time off Hr/Hin D E quivalent* COPMENTS: Min. 115B Reading co n tin u o u s Employee Elapsed Exceeded? a t End sound le v e l perform ing Tine Yeo/tto o f Day- !dA) normal d u tie s 784- - Spacklino' i 767 M 113.9/ l 13.9/ iS -'i ; 7:23 - - 7:25 6:57 Y....-.\ 22.9-. 6:53 Y 33.3 80.4 . 83.2 78.. . Crew.Chief- . 82 L ab o rer-U tility 772 Fork L if t 1 1 3 .5 / ** 3:50 5:35 N 4.6 70.5 68 P roduction Area 839 B u ty l-F le ) 902 Kwik-Seal j 113.9/ 8:54 _1 113.9/ / 7:29 5:39 N 6:51 H 29.4 83.7 81 Using S ta p le Gun 2 h rs. Butyl-flex package 13.2 76.6 75 Kwik Seal 2 h rs . 866 Panel Line 894 113.9/ 113.7/ 7:36 7:38 7:01 N 7:09 N 54.6 86.6 86 O perator 43.8 85 84 Crew Chief 789 Room 205 . 067 :' - IW & 113.9/ 7:41 'rJ-r.y'.a ...7 = 2 3 ; .. .. 34 ? ; 83 7:45 ' 7:30 N 14.0 77.5 82. Compounding Butyl 76 Sigma- Mixer Black- 763 E x tru d e r 113.9/ >/ 7:50 1. .1 6:34 N 13.6 77.0 76 W eatherstripping QUEST DCK IM ETEflS : 5383 Hope C aulk H in . 1. 7/ 1.76 7:52 2 :5 6 382 Y 3704' COTfOung Bra. 1. 89/ -< 7 :5 8 11:57 223 Y ' ---------- , 3622 Boon 205| 1. 72/ v ' 12:35 2 :5 0 135 N ** d o sim eter had lo o s e w ire a t end o f p.m . s a m p lin g . DUPONT MK-1 ON JUNE 1, 1983 " - ' 1 ... ; 784 Confound ............... Boots 7:49 3:10 7:41 N * " 90 + 16.61 s [lo g 0 2 .5 x T ) ; T = tim e in h t s . 2 0 .8 11.5 )-* . 5 4 4 .8 C a l. w ith * 8 0 .3 79 Heelaim McKamara la b e lin g q t . ca n s. 8 0 .0 -- a.m . o n ly * * 85.2 " B u ty -fle x- P kg . pkiTi* c n ly B4 .5 B4 2/ 22/83 Work Area Grab Samples - Noise: ~ :V -t Sample Location or Operation dBA Level Rope Extruder #1 MeNamora Stuffer Small Stuffer Q4-2 Kwik Seal Area General Compounding Flexiseai Room V!"' Room 205 - ... 'V ' Butyl-flex Line \ Rear, Wall At Operator's Station Background Level Background Level At Operator's Station Mixer #12 Ross Mixer Feeding cylinders . Metal plugs rotating, ill;drum . Operation station--Packaging ` J . -V- Labeling quart cans!of Derusto ' Minut-Solv #5 ........ ' Pn cl Room Elgin 2-stem .' .. \ . Struthers - Well Mixer Packaging Area Stapling Boxes Cylinder Feeding Compressed air moving .tube..bottoms.. : ... At Floor Level - 78-79 C 75 ^ 75 t- 75 85 80 36-88 95 87 83-86 87-92 87-89 : 97 : . 86-87 7 mm sr^r^i'To*- -'<;:-f--rt % ': ."..tcA*T-i f ,i- :':s r5'v'. V.J_ ' .-"."if -_- -./-'Trh*-t-nc;H>ttOirifaOlCNcauT.i-fTdjwvi:o^nv-~ DMifon SaWy hHvtotor*; 7 ^K ^^ C o l,a lb 2 1 S EXHIBIT '! w J-- if < {-& -(( ^ IdL September 30, 1983 Mr. David L. Harrison Safety & Regulatory Affairs Coordinator DAP Ine, P.O. Box 277 Dayton, Ohio 45401 Dear .Mr..,.Harrison: ..WUfea-';lJlvtlttvJoe'' Wanaluar1"t?nitn `1ah'Unflif' C n n tmKah' 0*11^1OOP. 'a>j..Rpeir :.-' disagreement with the asbestos section of our report concerning the industrial. . " :....... hygiene survey conducted:at the. Day ton: plant on May 31, June 1, and June 3. '-ieai'.^^^-tiA nalysla, of the. bulk samples of .talc for asbestos content was conducted :: light-'dis^'raioniSUIning microscopy..by an.' accredited .private . .. ;. r ' . i . : laboratory--NATLSCO (Nation^rTjOM'Control Sefvice3 Cori>oratIoh)i;iH ek5Qn o te:;-"'* ''--'];,; :-i;cC; ' V that this is a different method from the phase contrast and X-ray diffraction . . methods used by OSHA in the past. Polarized light dispersion staining ; microscopy Is a recognized method for asbestos identification and NATLSCO chemists report that their results are in line with t!se of the other laba participating in a round-robin survey conducted by the Research Triangle. . Please refer to our report page 2, paragraph 2. The controversy of the . . .. length-to-widlh ratio In asbestos determination between suppliers, who in general use" a 2S:l.\ratio,;.^:o.tlM r.i'l^raJjoriesiiJ)ov-UM the 3;l^ratlo .was.^mentipned... ' - ; previously. This controversy will "pfobabiy-coritinue. . . V. - 1 ; '- :. .. . . - . - . . ;.; Based oh present Information we1do hot' feel our report is In error and do - not intend to amend the rep o rt.H o w ev e r, we can assure you, as we assured .Mary -Gerard-before beginning the survey, that lha report is confidential, r- - Attached Is a copy of the Workers' Compensation Law of. Ohio, Section 4123.27 which should make it clear that information, obtained during the survey will not 1 ji'fWfvf'.- . -. ' I*i 'w-i. & g @ igkZi'A : s i i i f e a p i i:PcV*I-r'-:~/- t.- rvK~-riJT-iV> ' W':?. rV-i'' -Jr J>> ,` IS S s If you have any further questions, please contact me at 1(800)282-3045. Sincerely, ; ' s . v ' - . . : *. a ;,,. Uyn Priddy ' Director of ' rial Hygiene & Engineering A: SA-fe.' ; --v'':- ir" mm