Document peeYroj6yjQVg928GrOvromzX

FILE NAME: Union Carbide (UC) DATE: 1981 Sept 23 DOC#: UC346 DOCUMENT DESCRIPTION: Memo RE USAP Policy INTERNAL CORRESPONDENCE PLAINTIFF'S EXHIBIT UC-J014 MINING AND M ETALS DIVISION To (Nom) Diritto* IoqHo R. E. Byrne Metals Division Niagara Falls, NY Copy to W. C. Thurberi/ P. 0. BOX H KING CITY, CALIFORNIA 93930 o* September 23, 19^1 Orfgwiotf*9 D*pfc Answrmg Utir datii 5vb/f USAF Policy <yA Per our discussion last week, attached ia a copy of the revised USAF policy on the use of asbestos-containing materials, (it is essentially the same as that "suggested" by AIA/NA.) We are hoping the USN will do something similar. You will note that they make a clear distinction between friable and non-friable materials, which could obviously be very valuable for our business. The impor tant sentence is in the last paragraph of the policy: "When an asbestos-containing material is clearly superior in performance and cost, and the health and safety hazards are minimal, then the selection of the asbestos-containing material is warranted." This sounds like it was written specifically for our RG applications, and I think you should make sure that Bales personnel, distributors (foreign and domestic), "reluctant" customers, etc. are aware of the policy and the quoted sentence, which would even apply to drilling mud and almost all of our applications. I would sug gest you even go back to General Motors, Ford, RCI, Interplastic, etc., etc. I talked to Bill Krebs of GMC and a guy from Ford, and both were pleasantly surprised by the new policy. Maybe Jack Walsh can work on Uvalde with this. Good luck with it. John L Myers /dm UCC 001210 t f c k~ b L l L ^ ilk"" O ' PENTAGON TELEC0r.WUNICATI0N5 CENTER RTTEZVUW RUE8BJA0I02 2112130 ROUTINE ,__ _ R 3O1700Z JUL 01 S \ FM HO USAF BOLLING AFB DC//LEEE// TO AIG 9411//DAPD/DE// . , . r ROVKAKA/AFMSC BROOKS AFB TX//S6SF// RUVTNDA/USAFR&vriVILEMiR DALLAS TX//CR// RUCLHTA/USAFRGNC1VILENGR ATLANTA GA//ER// RUVWBHA/US4FRGNCIVILENGR SAN FRANCISCO CA//KR// INFO RUEAMQA/194T A5G WASH DC//DASJL// 2EN M3 USAF BOLLING AFB DC//DAFD/DADPL// ' RUEAUOA/K) USAF WASH 0C//LCE/LEE*/LEE/LEEES// RUCIF'GA/AFESC TYNDALL AFB FL//CC/OEE// UNCLAS E F T O SUBJECT: INTERIM MESSAGE CHANCE B1-2 TO AFK BS-1S. B JAN TS. 1. THE CHANGE IS A CLARIFICATION OF CRITERIA PROVIDED BY IMC BO-4 CONCERNING THE USE OF BUILDING MATERIALS CONTAINING ASBESTOS. 3 i k c b o -4 , p a r a g r a p h 2 .. a d d e d a n e w p a r a g r a p h 1 -3 0 . 1 t o AFM 88-15. PAGE 1-13. PARAGRAPH 1-38.1 IS HEREBY REVISED TO READ AS FOLLOWS: * 1-38.1. POLICY ON THE USE OF BUILDING MATERIALS CONTAINS ASBESTOS. SCIENTIFIC STUDIES HAVE SHOWN THAT THE INHALATION OF AIRBORNE ASBESTOS FIBERS AT LEVELS IN EXCESS Or THE PERMISSIBLE WORKER EXPOSURE LIMITS ESTABLISHED IN THE CURRENT OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION STANDARD (29 C.F.R. S 1910.1001) MAY POSE A POTENTIAL HEALTH HAZARD. SINCE THE USE OF SOME ASBESTOS-CONTAINING CONSTRUCTION MATERIALS MAV UNDER SOME CIRCUMSTANCES RESULT IN EX CESSIVE EXPOSURE TO CONSTRUCTION ANO MAINTENANCE PERSONNEL AS WELL AS TO BUILDING OCCUPANTS: THE FOLLOWING POLICY IS ESTABLISHED: A TRIADLE ASBESTOS-CONTAINING MATERIALS. FRIABLE ASBESTOS- CONTAIN'NS MATERIALS ARE THOSE IN WHICH ASBESTOS FIBERS ARE LOOSELY COUND AND WHICH ARE EASILY CRUYiBLED OR PULVERIZED. SUCH AS AIR-CELL ASBESTOS THERMAL INSULATION AND SPRAYEO-ON ASBESTOS MATERIALS. FR1ABLC ASBtSTl'S-COWTAINI.VG MATERIALS PRESENT PERHAPS THE MOST SERIOUS POTENTIAL HAZARD. ESPECIALLY IN RIP-OUT'"AKD DEMOLITION OPERATIONS. ACCORDINGLY: (1) PLANS AND SPECIFICATIONS FDR ALL NEW CONSTRUCTION AND MODIFICATION PROJECTS WILL BE REVIEWED TO IDENTIFY THE CONTEMPLATED USE OF FRIABLE ASBESTOS-CONTAINING MATERIALS. THE BI0ENVIR0M4ENTAL ENGINEER SHOULD BE NOTIFIED IN WRITING OF ALL PROJECTS INVOLVING THE USE OF SUCH MATERIALS. (2) SPRAY APPLICATION OF ASBESTOS OR ASBESTOS-CONTAINING m a t e r i a l s t o e x p o s e d w a l l s , c e i l i n g s , d u c t s , c o l u m n s , e t c ., is PROHIBITED. (3) SPRAY APPLICATION OF THESE MATERIALS TO SURFACES WHICH ARE NORMALLY COVERED BY WALLS. CEILINGS. OR SIMILARLY PROTECTED FROA' DIRECT CONTACT, IS ACCEPTABLE, PROVIDED THAT THESE SPRAY-ON COATINGS DO NOT CONTAIN MORE THAN ONE PERCENT ASBESTOS ON A DRY- WEIGHT BASIS. AREAS WHERE SUCH COATINGS ARE APPLIED MUST BE IDENTI FIED IN REAL PROPERTY RECORDS AND BIOENVIRONMENTAL ENGINEERING CASE FILES SO THAT PROPER PRECAUTIONS KAY BE TAKEN DURING MAIN TENANCE OR DEMOLITION ACTIVITIES. (4) OTHER FRIABLE ASEESTOS-CONTAINING MATERIALS ARE ACCEPTABLE ONLY IF INDICATED BY A SUBSTITUTION STUDY CONDUCTED IN* ACCORDANCE WITH PARAGRAPH C. HEREIN. (5) IN MAINTENANCE. MODIFICATION OR DEMOLITION ACTIVI TIES WHERE EXPOSURE TO ASBESTOS DUST FROM PREVIOUSLY-INSTALLED FRIABLE AS8CSTDS-CONTAINING MATERIALS HAY OCCUR. ALL AVAILABLE PRECAU1 IONS. INCLUDING THE USE Or WORK PRACTICE. RESPIRATORY PRO TECTION. AND INDUSTRIAL HYGIENE REQUIREMENTS Or CURRENT OSHA ANO FEOSir.. .-ACT AFDSC...ACT AFIS VIA IN. ..ACT 1947ASG...INFO HO USAF AINCTTOION L19T<E7(A2S>G(F5U)E DACY((11)) 1 1 . * * 9 (A.F) KCN=l; '312/02011 TORTI3I2/0136Z ;jp FORCE MESSAGE. fjV yiTT.JI /> Q Q J? TA0*812l2/02l0Z l ^ |~ CDSN'MAPSIS *AG t 7002 JUL Cl UNCLASSIFIED EFTO . PENTAGON TELECOrmjNlCATlONS CENTER EPA REGULATIONS (79 C.F.R. S 1910.1001: 40 C. F. R. S 61.20) SHOULD BE STRICTLY ENFORCED. B . NON-TRIADLE ASBESTOS CONTAINING MATERIALS,. NON-FRIABLE ASBESTOS-CONTAINING MATERIALS ARE THOSE IN WHICH ASBESTOS FIBERS ARE "LOCKED-IN* OR "ENCAPSULATED* 9 A MATRIX MATERIAL. SLTURANT. IMPREGNANT OR COATING. NON-FRIABLE ASBESTOS-CONTAINING MATERIALS DO NOT RELEASE AIRBORNE ASBESTOS FIBERS DURING ROUTINE HANDLING. AND END-USE. "SOKE NON-FRIABLE ASBESTOS-CONTAINING PRODUCTS. IN CLUDING MASTICS AND BLACK LINE PRODUCTS. MECHANICAL PACKINGS. OIL SEALS. COMPRESSED GASKETS. SEALANTS AND CAULKS. ANO ELECTRICAL INSULATING PAPER. 00 NOT RELEASE AIRBORNE ASBESTOS FIBERS IN EX* . CES5IVE QUANTITIES UNDER ANY REASONABLY FORESEEABLE CIRCUMSTANCE. OTHER NON-FRIABLE ASBESTOS-CONTAINING MATERIALS. INCLUDING ASBESTCSCIKENT (A-C) PIPE. A-C SHEETS. RESILIENT FLOOR COVERINGS. AND ROOFING FELTS. KAY PRODUCE EXCESS DUST LEVELS DURING CERTAINUNCONTROLLED ABRADING. SANDING. CUTTING. MACHINING. REK3VAL OR DEMOLITION OPERATIONS. BUT VILL NOT DO SO IF CORRECT WORK PRACTICES ARE EMPLOYED. ACCORDINGLY: (1) PLANS AND SPECIFICATIONS FOR ALL NEW CONSTRUCTION AND MODIFSCATIDN PROJECTS WILL BE REVIEWED TO IDENTIFY CONTEMPLATED OPERATIONS IN WHICH NON-FRIABLE ASBESTOS-CONTAINING MATERIALS WILL BE ABRADED. SANDED. CUT. MACHINED. REMOVED. ETC. THE BlOENVIRONKcNTA L ENGINEER SHOULD CE NOTIFIED IN WRITING OF A LL PROJECTS INVOLVING SUCH OPERATIONS. (2) SUCH OPERATIONS SHALL PROCEED ONLY IN ACCORDANCE WITH SPECIFIED WORK PRACTICES WHICH ARE KNOWN. OR HAVE BEEN SHOWN. TO PREVENT EXCESSIVE EXPOSURES TO ASBESTOS DUST. WHERE APPROPRIATE. DATA SHALL BE REQUESTED FROM THE MANUFACTURER DOCUMENTING THE EFFECTIVENESS OF RECOMMENDED WORK PRACTICES IN PREVENTING EXCESSIVE EXPOSURES. (3) WHERE A NON-FRIABLE ASBESTOS CONTAINING PRODUCT CANNOT CE USED CONSISTENT WITH CURRENT OSHA PERMISSIBLE EXPOSURE LIMITS. OR WHERE MANUFACTURER DATA DOCUMENTING THE EFFECTIVNESS OR RECOMMENDED WORK PRACTICES HAS BEEN REQUESTERS BUT NOT SUPPLIED. THE USE OF SUCH PRODUCT IS ACCEPTABLE ONLY IF INDICATED BY A SUBSTITUTION STUDY CONDUCTED IN ACCORDANCE WITH PARAGRAPH C. HEREIN. C. SUBSTITUTION STUDIES. WHERE REQUIRED BY PARAGRAPH A. Oft B. HEREIN. PLANS AND SPECIFICATIONS FOR NEW CONSTRUCTION AND MODIFICA TION PROJECTS WILL BE REVIEWED TO INSURE THAT CONSIDERATION IS GIVEN TO THE USE OF ASBESTOS-FREE MATERIALS. THIS REVIEW SHOULD COMPARE THE COSTS. PERFORMANCE CHARACTERISTICS. AND EXISTING AND POTENTIAL HEALTH AND SAFETY HAZARDS WHICH MAY RESULT FROM THE USE OF EACH TYPE OF MATERIAL. WHEN AN ASBESTOS-CONTAINING MATERIAL IS CLEARLY SUPERIOR IN PERFORMgr ANB gP5T."JRB' THE H E A I T ^ ANP" S A F E T Y h Z?ARDS ARE MINIMAL. THEN THE SELECTION OF "IHE ASBESIUS-CDNTAIN1NG MATERIAL t s W a r r a n t e d _ h o w e v e r ."w HEH AN a s b e s t o s -e k e e MAitxiAt W i t h n o n HAZARDOUS CHARACTERISTICS AND COMPARABLE PERFORMANCE AND COsT IS AVAILABLE. THE SELECTION OF THE ASEBESTOS-FRE MATERIAL IS INDICATED. IN SITUATIONS WHERE THE APPROPRIATE SELECTION OF MATERIALS IS NOT READILY APPARENT. SELECTION WILL BE MADE BASED ON SOUND ENGINEERING PRINCIPLES AFTER A DETAILED ANALYSES OF ALL FACTORS ASSOCIATED WITH EACH ALTERNATIVE. BT . _ . . MCN*B1212/02011 -iio FORCE MESSAGE* p f r\ TOR-01212/013RZ TAD8121?/02102 P f~ r CDSN-MAPS15 v-'.P'GE 1 OF 7 m t o o z jul 81