Document qkYOomD9onyz8Y8VM68Q2vMvk

FILE NAME DuPont DUP DATE 1973 Jan 12 DOC DUP146 DOCUMENT DESCRIPTION Letter to L.C. Hentz Clinton Plant from James F. Morgan RE Asbestos  . C 00227 Jamuuary 12 1973 L. C. BENTZ CLINTON PLANT FILM DEPARTMENT ASBESTOS At the requeofst J. E. Gentry I have reviewed your letter of October 19 1972 to J. B. Howard and offer the following suggestions 1. Permissible Concentrations of Asbestos Dust the The regulation promulgated by U. S. Department of Labor and pub- lished in the Federal Register June 7 1972 includes the following b Permissible exposure to airborne concentrations of asbestos fibers - 1 Standard effective July 7 1972. The hour time weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers , longer than 5 micrometers per cubic centimeter of air as determined by the method prescribed in paragraph e of this section 2 Standard affective July 1 1976. The hour weighted average airborne concentrations of asbestos fibers to which any emplomyayebee exposed shall not exceed two fibers longer than 5 micrometers per cubic centimeter of air as determined by the method prescribed in paragraph e of this section 3 Ceiling concentration No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers longer than 5 micrometers per cubic centi- meter of air as determined by the method prescribed in paragraph e of this section Please note that a time limitation on a ceiling concentration has not been adopted in the regulation except insofar as any excursion above the average permissible concentration must be compensated for by a similarly lengthy ex- cursion below the average ; L. C. Bents - Janu1a 2r 19y 75 2. of CompliCoampnlicane ce The respi ofrra est pio rar tos rs should never be listed first among items pro- posed for reducing the creation and dispersion of asbestos dust Please note the following copied from CFR 29 - Part 1910 Occupational Safety and Health Standards Federal Register p 11319 June 7 1972 2. Methods of compliance It has been pointed out by many persons that protection against asbestos fibers is best obtained by controlling the generation of fibers first and secondly by controlling the dispersion of released fibers into the ambient air of the workplaces Therefore the standard requires feasible technological controls and appropriate work practices as the primary means of compliance Rotation of employees as a way of meeting the TWA concentration requirement is allowed only in stated exceptional circumstances because as a general rule it would be difficult to implement Personal protective equipment such as respirators cannot be relied upon because among other reasons they may be so uncomfortable as to be burdensome except for short periods of time Thereforiet is expected that respirators and shift rotation will be used during the period necessary to install engineering controls and to train employees in sound work practices but after technological com- has been achieved their use must be limited to special work situations and emergencies Where both are practicable shift rota- tion is required 5. Medical Examinations According to the law initial examinations of each and every employee shall be completed on or before January 31 1973 examinations shall be done annually thereafter ORIGINAL SIGNED BY JAMES E. MORGAN JAMES F. MORGAN JFM Enclosure Rules & Regulations - Federal Register Vol 37 No. 110 Wed. June 7 1972