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f FROM E. E. RUMBERGER PITTSBURGH OFFICE - 6 TO MR. J. R. ARCHIBALD - PGH. 6 1981 February 18 RE: ASBESTOS During recent conversations, there seemed to be some doubt as to what has been said to plants on asbestos and, especially, finding suitable replacement materials. The six attached references will provide you with a chronological overview. (The attachments are arranged in reverse order, with the latest information on top.) 1. 1971 DEC. 23 -- R. P. Carter alerted Industrial Hygienists and Safety Directors on a ' proposed OSHA emergency standard for exposure to asbestos dust. 2. 1975 JULY 22 -- R. P. Carter issued an "Industrial Hygiene Newsletter" to hygienists and Environmental Committee Chairmen, with copies to R. H. Watson and B. D. Dinman advising on new proposed OSHA standard with tighter restrictions on asbestos exposures. He suggested that " ... further effort should be devoted to finding non-asbestos alternates..." in lieu of the cost of the control measures required. 3. 1975 NOV. 19 -- R. P. Carter issued an "Industrial Hygiene Newsletter" to hygienists, with copies to physicians, Environmental Committee Managers and Committee Chairmen, R. H. Watson, and B. D. Dinman. This was a specific discussion of the new OSHA limit of 0.5 fibers per milliliter to be effective 1976 July 01. On Page 5, he states that this new regulation offers " ... further incentive for every location to discontinue the use of asbestos of all forms to the fullest extent functionally feasible...". 4. 1976 MARCH 30 - R. P. Carter and M. J. Caprio issued a letter to hygienists and Purchasing Agents, with copies to R. H. Watson and B. D. Dinman. This letter promotes the change to non-asbestos containing replacements and recommends sources of information. 412769 0082 Dr. B. D. Dinman Mr. J. R. Archibald 1981 February 18 Page 2 5. 1978 JULY 28 -- T. B. Bonney issued a letter to hygienists, with copies to J. R. Archibald and B. D. Dinman. He acknowledged that the plants were making progress in eliminating unnecessary asbestos usage, but allowed that there were still many asbestos products being used. This letter initiated a plant survey of various categories of uses and replacements that had been found suitable. 6. 1979 AUG. 27 -- E. E. Rumberger issued a cover letter to Location Managers, with copies to Safety Managers, Purchasing Agents, hygienists. Environmental Managers, and J. R. Archibald and B. D. Dinman. This letter discussed "Alcoa's Asbestos Replacement Program" and provided company technical references for finding replacements. It served as a cover letter to extend the distribution of Haig Sakoian's report on "Asbestos Substitution dated 1979 July 30. This was a comprehensive report that summarized the progress of different plants on finding replacements for specific end uses. The second part of the report specifically discussed potroom uses. This was the culmination of the plant surveys started by T. B. Bonney in 1978. In August of 1980, we felt it desirable to update the progress on asbestos replacements and M. J. Vaudreuil canvassed the plants for their reports, which came in during September, October, and November of 1980. During that time, Mr. Vaudreuil left Alcoa's employ and the asbestos responsibility has now been recently assigned to R. W. Flanagan. He now has the task of putting the feedback from last fall into a new status report to be distributed to the plants. This letter and attachments should give you a picture of Alcoa's activities through the past ten years but, more importantly, the communication efforts we have brought about within the past two years to continue to foster replacement efforts. While progress continues, there are some locations which have been slow to act in finding substitutes. This was the reason why I suggested that we give some consideration to an "Alcoa Health Guideline" or "Objective" that clearly delineates for location management the Company's goal to eliminate asbestos insofar as is practicable. E. E. RUMBERGER EER/eds Attachments (6) 412769 0083 FROM E. E. RUMBERGER PITTSBURGH OFFICE TO LOCATION MGRS. - DOMESTIC & CARIBBEAN LOCATION MGRS. - SUBSIDIARIES & ALLIED PRODUCTS 1979 August 27 RE: ASBESTOS The attached memorandum on the status of Alcoa's asbestos replacement program was recently released to all location Industrial Hygienists. Because of the impact of asbestos use on each of our locations, I felt it important that you be aware of this information. Works Safety, Environmental, and Purchasing Managers are included in the distribution of this letter. The asbestos problem, from a health hazard and governmental regulation standpoint, has not diminished in the least. In fact, implications are that asbestos control regulations will become even more stringent in the future. For these reasons, we are currently stepping up our coordination of this program to find substitute materials wherever possible. The corporate Industrial Hygiene staff will monitor feedback on the testing of replacement materials and maintain the continuity of the program. Technical expertise on asbestos substitutes will be provided by each of the following personnel in the areas indicated: H. G. Sakoian (Pqh.-Ind. Hygiene) -- Overall Coordinator M. J. Caprio (Pgh. Office-Purchasing) -- General Insulation; Molten Metal Marinite J. M. McCollum (Pgh. Office-Mechanical -- Potroom Replacements Engineering) D. St. Jacques (ATC-Safety) -- Personal Protective Equipment Please distribute this information to other appropriate personnel on your staff as you see fit. E. E. RUMBERGER EER/eds Attachment Distribution: See Page 2 on Reverse Side UJ ALCOA 412769 0084 FROM HAIG G. SAKOIAN PITTSBURGH OFFICE TO MEMORANDUM 1979 July 30 RE: ASBESTOS SUBSTITUTION Attached is a summation of asbestos materials currently in use at Alcoa locations. Included in the listing are: The material and its use The number of plants using the material - Whether or not there is a potential for employee exposure Potential replacements, if available -- and manufacturers (Page 10) Much effort has been extended to reduce and eliminate asbestos uses in most locations. However, as can be seen by this report, many uses still exist. Because the continued use of asbestos products may result in unnecessary health hazards and concerns to our employees, as well as additional costs to Alcoa to comply with specific provisions of the OSHA Standard, we believe it is in Alcoa's best interest to continue eliminating the use of asbestos products wherever possible. This does not mean that all existing asbestos should be removed immediately which, as in the case of sprayed-on insulation, could create unnecessary exposure potentials. Rather, a systematic effort should be made to discontinue uses, when feasible and practical, by substitution or elimination. By creating this listing and maintaining frequent updating via feedback from all locations, each plant can be provided with the information necessary to attain this goal. Mr. J. M. McCollum, Pittsburgh Office Mechanical Engineering, has been coordinating such an effort for asbestos replacements in potrooms. A list illustrating Alcoa's experience with potroom replacements is shown on Pages 7, 8, and 9. It is hoped that this type of registry will be extended .to cover all asbestos uses for all locations. To achieve this, it is asked that each location copy this office on all efforts made towards asbestos replacement... whether positive or negative. This information will then be disseminated to all locations on a periodic basis so that each plant can profit from the experience of the others in the Company. Any questions, comments, or additions to the attached would be appreciated. HAIG G. SAKOIAN HGS/eds Attachments Distribution: See Page 2 UJALCOA 412769 0086 memorandum 1979 July 30 Page 2 Distribution: Industrial Hygiene Newsletter R. G. Labar - ATC N. Kloap - Arkansas Works R. C. Hinkle - Badin Works R. Karstensen - Mosal Aluminum, J. Rob - Mosal Aluminum, M. J. Caprio - Pittsburgh J. M. McCollum - Pittsburgh J. Z. Nelson - Pittsburgh E. L. Rooy - Pittsburgh G. F. Stephens - Pittsburgh D. D. 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C/3 412769 0091 in a) O' f(a0 w PI m in -P P a) 6 (U os x UK P rtj P X 'H P XI a W 4H nS 4J nS P fa 05 O P * P,-P O a fa 05 fa 2 (0 Eh as X *'P ns us XI lwP in M Hns P O ns-p O ns X! > P O nS fa ns e0 m p a cn -p oc pp H *rt *H g H in ts o ns P nS P in -h 4-1 P S Cu 05 TJ p XI i ns p ns o as 13 E o 1 as ic p m in 2 ns o H -P S n p in p D as > -p Xl xl u ns in p u 6 ns o CO > >1 P ns p Xl p x: -p nS P Xl d x: -p ns r--i -p o c -d P P PPpp P >4-1 o 1--1 0 Um cPn w P -P P om n^ p otv. ov Cn PP p O p tp nS P P in ip 0 ns g ns p P u> ns o p p oo P O -P - X! U 03 P O P -P O p *d p p xfl in o in o p Pm -H o cu cu d-P - r-i 4-4 -P C -P Old) p ns P a p P OPO O .. d 4-> -P - O CP MU -P u m in t3 -p -p ns in o p p P CTsep'd'O .x >d ns D p o p p -p P P XI * p ip O X r- E POP ro rp _ ns 3 CU O -P O *P dp v cn .. 04 P P - >i `>|IOH 10 ao. x w x5-PO-P-Pinpn3 in p p 013 in p o p P ns p p P X5 -P ns m o CU-P in PM in cu P in >d -p ns PC x: p o p ns 03 4J O +J P^ PPOcu O> P>p rp VHD .. O -P ns l4J'P P M PP E nS O > XI ip' JQ O ns P -P P P - o nS tn ns o p P cu c P as s m O w 3 CU <H t> P o O -P T3 O P -P cn -gP in -P o ns -P id (--j -p >1 P ns >i P CU P u 03 -P P XI nS O P X P p O* a O -P -P 2 nS P *p xj p ns 0 rP 2 nS --l CUX! O P -P ns (0 H O P CU -P hot P XI cu O -P in P cu p -P o X ns p OOP H &h ofa o P -d c m P P P 4-4 P P ns a c H <N CO >i-p *d o p w ns ip P -P N >i'-- OX * n +J x: E *> d O CU >41 X5 p O -P POO' +> O XI 4-1 x: -p O 4-> 4-1 * ns P 2Q Number o f p la n ts u sin g m a te ria l a p w rI CO -P o \ ,X a in n) M C3 -p 05 c W P o Eh u X5 CO c o P P ' ns in p pP \ ns in cr P P cn -p -p X3 p EP-t o ns ns P P PP OP CU fa Cn O p p 5 p a p o o o p O Xfl 412769 0092 Page 6 KEY TO ALCOA LOCATIONS 1 -- ATC 2 - ARKANSAS 3 - BADIN 4 - CHILLICOTHE (Wear-Ever Aluminum) 5 - CLEVELAND 6 - CORONA 7 - DAVENPORT 8 - FT. MEADE 9 - LAFAYETTE 10 - LANCASTER 11 - LEBANON 12 - MARSHALL (ACPC) 13 - MASSENA 14 - MOBILE 15 - NORTHWEST ALLOYS (ADDY) 16 - PT. COMFORT 17 - REA MAGNET WIRE 18 - RICHMOND, INDIANA 19 - ROCKDALE 20 - TENNESSEE 21 - TIFTON 22 - VANCOUVER 23 - VERNON 24 -- WARRICK 412769 0093 s to atr) CiLd, 'Oa> H Pp ? -iPd 0) o o O' >Id1 4-> X a> w O 4J 3 *<au W >i0d -n 4oJ ea 0(U 3 0c' a to 43 H PP O 3(U 3(d 3 40JJ Pa 1 to O- Hto H.-4 xj P 3 ptfl Oo>' pp a) 3 u <au ta)) Pto Pm a) a 4J P a) o> xs XJ Po Po id n> -H -H P Pa) 4J P id id EE T3 43 0) 0) >> H -H a) a> o > H (0 CoQ oo 3 co H <d 4J X * 0P a in 1 a o 3 u<d i*Ho k 03 l 4J P0) to to O' P P 3H a) 0) -P XI XJ to 0) o o Eh EH 4 a> 4P3 ' P O P .H-4 4O4 -p*4 PO to P to -- d) a 4J o id *pH E H C d) ax O >1 r4 O' P o * rH -p CinM CinM oG id - o o c pp C '-- --HH4dP_3> -to 44 1 1 - H p p CO a a O' CO 3 a <0 3 -h 3 P 44 d) 3 B-H ap u OOP O T3 Id o to 3 3 10 43 3 O T) d) 03 id -H P P to HI 111 P d) P to 3 pp p to to >1 to to *o 0) 0) o P XJ *> dl dlr44) PPPP Po O O' d> P o 3 3 XJ 43 V d> d) d) 0) to O' p XJ XI P XJ to AJ o -H to 0) p 0030 <0 O P E OO E-i E4 frt u &l Q 1 d) tcwoo 4C3J P M O H id U (d c a> (0 id id 33 d) to to to s U CQ to co S d> flj id ;S & S id id SS o o a 0a 1i to o E-i tWmtofl < <D p P 3 d) 43 PH to Pto d) aoz o X3 1**4 o o W3 P H >i H H P Cl4 P1 1 id g 6 39 9 aa a P s d) r- 43 X 0) ss Ch JC o aa O1 <0 r4 P -H -H a3 1 *H EP 3 id uS r~i i--1 dl 43 to p p o a P O3 a OrM oP p r-H r-d4> o CQ 4id3 HG p a id p 33 p o OH 3P PP r<H0 to p 3CQ d) a HG C3O (d id id c ' 33 a) 0) 0) 0) co to co CO to <d id id S ss X o 3 -H -w p T3 p id id 0J 0) 43 u p id 3 d) & 1p 0} 0) 0) 43 *-4 u to Id . G to (0 H Hi to tUHo P CQ <d jf P H 0) CT | X> a I -uH* Ea O -h p o XidI tu > o XmJ <d i co to < Ea 3 OH P riHd 3co M3 P d) > 0 u p a0 ttoo ,--idi co 0 dEp) 4E34 0irn41 tao X(0 roI pid =e#>= id id id XX 3 33 oo (0 <0 d) 3 3 H -W CO CO id to t0-H-H to to >0 'O id id id id PP PP id <d E s s hj m 3: 3 oo O' \rdPtJ-Hs d) P P tdo> s tj d) id id CX OH Id to XI c3o o E p d) 43 P OP a i0n 1 S p oiod -J!* Jsr*=r4 Hn I I in i -h a a C3 ai i i E p PP UJ-d o -fHi -H 43 cp iPd o pH -pH pO mO oa sid sida>, E r*4 O O O3 aid r004a E E1h **4 C3 ad) p oso Cn *bH p id P o s Ho P id >ir4 412769 0094 0) CO 0) O' id 04 to d) X9 X O' c P X (0 d> TJ TJ X d) i Xw -mP rltltl XXX tGltio p x> x P 900 U Eh Eh a > a >i (d to s c id x GP id 4o<-*k X tJ ma) spc' mc x id s >1 co PX\ >1*0 GC o id E rH h tj id . Gp H0) pE Id X r*i tji id -h C -P H J C -H id X i o G id o 2 p oo ac <-l TJ X m -p id s d> X Qi P CO t> <D x > to O' a> c a-H iH c GH <Ut|>P a) s Oi P O tj .* to *h Oi 0) m to o > P o ip a) x at o O < O H p -H i-H X ox p oh n Dm m * <uo o> c c a) >EPGd)idPX Xo o id 0) >iV p ti cxco.qtjxxx n id Xo P a) p a > to O to P o o O-P m o X >i G X to id x O X a) id i-H to in a IN iH 0 (0 O Oi O 9-0 9 in CM PG O2 CP oo o to d 0) p P01 CM 1 O TJX -a T> 0) o ip E 04 c 0) G X TJ id ** x id id tj C to to to x o> ro d oxxoxxmo G id i--idi Q. O Z t0j) x to a) Eh a x x x x to h Qp >cidocidaJa3>cidQitdaidO<-P p a) Eh o z ASBESTOS -- POTROOM USES 0) C 0) 0) O id id P c c X id iHc a> 0) <D 01 o TJ co 0) o id id id X CQ 2 2 X roH p p id 5 X o X id G 0) S XO -P id 09) O E< S P HP -P 1 0) 04 w to a> x 9O Xc H 0) X * id e G9 -rl >d EG S9 rH P O CN X X O' id p p id G X CJ op p d) >1 X XX 0) H S U-t c o0 H 'H <W id rM P CO G M CO p CO X up 90 aX d X rH to 9 9 to id c XH X w rH 0) id d) 04 04 ro rH id p >--1 1--1 d) 00 0) \ u CO id id x rH Id v 0) X o 4-> to to 04 1 XX id p p= 4> d> 0) TJ Jf <D m a> 2 X XG > rH pH p p id i 0 1 04 --to 04 XX s rH id to JC* t Eh CO S CO rH CO Id (U ao <d X X 1 id 0) P d) d) X CO Qi (U X XHH 0) pe u o o 1 d> o o p P U 04 .Q U s >1 >1 CO H t 04 Oi Pp x c uo CO X CD X ro id O CO X a> oM 9 CO Q id o X CO c 9o id x: Xa X H 01 CO 412769 0095 ASBESTOS -- POTROOM USES ound F-10 D -l F-10 0) X10 P d) <4-1 P 45 10 d> 10 0) <D m p c d> n p p i Q av <D O' f<a0 P H g T3 ^ p i a) -p -p XI <1-1 0 0 \g 3 c 45 45 <0 3 >H P M-| a . p O p p <o a) o 10 0! o TJ VO 3 43 O C -P tn op CO <0 O -P O WZ oa a> CO D <a 0) >0 C o -H c a G 9) c n os P -H H ffl O P <a T3 S 10 10 S 10 n Q0 G .3 +fa1 P H (0 p10 i P a <0 <0 ao01 45 a p 45 3 P= o\ a10 p 3 maoi --1 <mAo <D n 1 43 P <u 1 H P45 C H <D-H o a) n 45 a Chl 0) a 10 45 P 3= H4SP UJC -H 0) 1 CO ftS iH 11 0) a 0) 0 ap o PH 10 rH <D 10 01 O 01 P9) P 45 01 -H 4) fa -H fa = PC' =1 HH o H PI <D i--1 C *o O <0 H PI P 10 <-a o r--1 H dl id rH o Oa, <o CO (0 *3 P) 1 412769 0096 ASBESTOS REPLACEMENT MANUFACTURERS PRODUCT___________ Pyro^texT SUPPLIER Newtex Industries, Railroad Ave. P.O. Box 25 Victor, NY 14564 Inc. Fiberseal Products Pyrotek Incorporated East 9601 Montgomery Ave. Spokane, WA 99206 - or - Box 77 - R.D. #1 Claremont Rd. Carlisle, PA 17013 - or Santa Fe Springs, CA Refrasil HITCO Division of Armco Steel Middletown, OH 45042 Nor*Fab Yarns; Fabrics Amatex 1032 Stanbridge St. Norristown, PA 19404 Fiberfrax The Carborundum Company Insulation Division P.O. Box 808 Niagara Falls, NY 14302 Hi-Temo 270 Penn Compression Moulding, Inc. Burton Street Pittsburgh, PA 15218 Ceramic Fiber Pro^gtS. Kaowool Babcock & Wilcox Page 10 TELEPHONE 716/924-9135 509/926-6211 717/249-2075 215/277-6100 716/278-6221 412/351-4004 Cem-Fil Corporation Two International Plaza Drive Nashville, TN 37217 Keller Glove Mfg. Co. Plumsteadville, PA 18949 . 615/361-4664 215/766-8818 HAIG G. SAKOIAN 1979 July 20/eds 412769 0097 FROM THOMAS B. BONNEY PITTSBURGH OFFICE -i TO 1978 July 28 RE: ELIMINATION OF UNNECESSARY USE OF ASBESTOS-CONTAINING MATERIALS Over the past six years, primarily by means of Industrial Hygiene Newsletters, we have attempted to discourage the use of asbestos at all of our operating locations. We have taken this position for two reasons. First, excessive , exposure to asbestos represents a real hazard. Second, compliance with the applicable OSHA standard costs us money which we would not have to spend If substitute materials were used (e.g., for air sampling, medical surveillance, disposal procedures, etc.). Although our plants have made Impressive headway, it appears that our goal of eliminating unnecessary asbestos usage Is not yet at hand. As we visit our plants, we still see asbestos products being used. We suspect that for many of them there are asbestos-free, functionally acceptable alternates. Because continued use of asbestos products may result In unnecessary health hazards and concerns to our employees as well as additional costs to Alcoa to comply with specific provisions of the OSHA standard, we believe that It Is In Alcoa's best interest to eliminate the use of asbestos products wherever possible. To accomplish this objective requires that first we know for what specific applications It is presently being used. Therefore, we request that you survey your location to provide us with information about your plant's use of asbestos. The attached form indicates the data that is required and can be used for submitting your survey results. We ask that you submit the results of your survey by 1978 September 01. Upon receipt we will compile a listing of current usage throughout Alcoa. With the assistance of appropriate plant and Pittsburgh personnel, we will place each usage Into one of four categories: (1) No foreseeable employee exposures; substitutes available. (2) No foreseeable employee exposures; no viable substitutes available. (3) Potential employee exposures; substitutes available. (4) Potential employee exposures; no viable substitutes available. Following classification, with the aid of appropriate Pittsburgh and plant personnel, we will work toward a prompt and orderly replacement of all Items in category "3". Jointly, we will further consider If there Is merit to taking the same action for any or all of those materials In category "1". *3ALCOA 412769 0098 '1978 July 28 Page 2 This, of course, will require a determination of whether the economic consequences would justify such action. Our ultimate aim Is to provide the plants with the information necessary to attain effective control over their use of asbestos. To help accomplish this, we will provide you with information about substitute materials. Eventually, we will publish a list of "approved" asbestos products and applications (l.e., those for which there are no currently viable substitutes) to offer guidance for purchasing, production, industrial hygiene, and other interested plant personnel. We ask your cooperation in collecting the information needed to make this possible. THOMAS B. BONNEY TBB:lmn Attachment Letter sent to Industrial Hygienists Copies sent to: M. J. Caprio, Pittsburgh 19AB J. Z. Nelson, Pittsburgh 3WPH N. Kloap, Arkansas Works R. C. Hinkle, Badin Works J. 0. Breazeal, Davenport Works H. E. Chandler, Tifton R. K. Morrow, Massena Works E. B. Parker, Rockdale Works W. S. Stroud, Tennessee Works O. A. Blessinger, Vancouver Works G. H. Farrah, EHL, Alcoa Technical Center W. W. Williams, Fort Meade, Fla. J. B. Dolan, Lafayette Works G. R. Hartnett/Albert Lee, HC Products Co., Princeville, 111. J. R. Archibald, Pittsburgh 7AB P. R. Atkins, Pittsburgh 7AB B. D. Dinman, Pittsburgh 7AB W. B. Garyotis, Pittsburgh 2AB R. V. Newsome, Mobile Works 412769 0099 Item P> 3 cc oc a 2* c c CO >0J Oi o41-0 4J c o c 2 Dust Generated? - ASBESTOS SURVEY I-1---------------S p e c ific A p p lic a tio n Product Description^ CO t. o - cm CO nt tf> CO N oo a\ o - CM 13 o J0Z COO P> -P CO M Oi JO C<Oo 0i c co o 3C o X CO o * .G o 36 0i co 1<0 O G CfO UP 33 CLjQ OI 01 C Cl *- to 0J r-- -Q o. ^>1 c p c r-- 01 s- r-- T- c P> 3 CO u Oi CO 1. p id o 3 p *3 40 O JC CP Ol 0 C0O r-- CMO Sr-. 01 01 -1Q0 P0 <0 E r- 0 r- O lO 1O -P00Q1* "OOI 4-0<o 03 CO CO OI O Oi C ^ r-- ^ Pr-*0l 4Q lO X Ci 4P r- CO > 4- C r-- r- T- /P UC ai >> oj Q--- C00C 33 Oi o o "O f- 3 > 01 -- 01 C. U C 40 ca -r- 40 01 PI OX c r- 3 01 3f-e o Ci OI -C c o CO *- 40 r-- pp a CO O 01 T- C S- -1 ., -- 01 p o 2? I I c-- C 0 10 H- O *- +J O UC 0 4- C 0) U r-- --' o> o -Q .n 4-> cn 40 *r- C cm- 0>r- <0 Cl. Cl "O f- 3 Oi TJ XJ *o P C 01 40 O >> 1- e cx^ Oi T UC ^*o-- p CO 01 C. o 40 Oi pi c co o CMC Cl o "3 Oi *o oi -O 0i*--* P> 1. OI 40 3 QIC r-- 0 40 OI 4Q C C 2 Oi E 01 > OI Ok P 40 u301 T> o> *D4J aif PC<. t-** JQ ar- Ok 4-> < 0 Oi CO i- 2 3 Oi 1 *o 01 o> C T- E C O *f- *- O f- p P CO 40 O *EPS t- 40 C co o r- E O 01 -C CO 4- jQ 1 -Qr- fC- VOIJPZ 0 O>0 0i f- *- O Gl *.n- o--a'i a-n9 <o 0 o> r- C U -C U T- O O P*^ > 4J t t a <o ud oaj voi Q- C t 0j p oi o> c l. C Ui3 O 01 c o-g 1-0**- 2 uu o 3 +-- a ai * <4O tc o O *- >to?c* -O O CO 0> P V. -C co CaO) 03 O) 40 CO0O)i Q) o> r-P OO C C C Xx C 40 Oi r- U *r* C ^3 *o*-t- 01 c c a<jij r-- 0O 01 P)C 2 T- 40 tO CO 40 P 3C c0o *f P O Die co *.Q oi X p40 p4-0Sg *0 #-- 1-1Oi P> Pc>o O*- 3 O3 C C Oi +* o Oi Oi JC Ok o 00 \ CM 01 P o z in 412769 0100 ' Letter 1978 July 28 re eliminating asbestos went to the following industrial hygienists: D. E. Thompson, Addy, Washington 0. E. Wilkinson, Anderson County Works J. M. Plunkett, ATC J. F. Dey, Arkansas Works Earl M. Morgan, Badln Works V. Locke, Jr., Wear-Ever, Chllllcothe L. L. Grubb, Cleveland J. V. Muncle, Corona K. W. Williams, Davenport S. Huey, Rea Magnet, Fort Wayne W. D. Coker, Lafayette L. M. Crlvaro, Lancaster R. Andrew, Lebanon W. D. Helmlck, Logans Ferry T. V. Byerley, Marshall G. 0. Hicks, Massena W. J. Boutrels, Mobile R. E. Podhora, Point Comfort J. D. Gibbs, Richmond A. G. Clayton, Rockdale J. C. Vergho, Tennessee L. L. Halsch, Vancouver D. P. Hooghklrk, Vernon R. L. Parsons, Warrick 412769 0101 ROBERT P. CARTER HEALTH & ENVIRONMENT DEPARTMENT PITTSBURGH OFFICE, 7AB & M. J. CAPRIO PURCHASING DEPARTMENT PITTSBURGH, 19AB TC 30Mar76 RE: ALTERNATES FOR ASBESTOS AND ASBESTOS-CONTAINING MATERIALS In October, 1975, the Occupational Safety and Health Administration (OSHA) published a proposed revision to its standard for worker exposure to asbestos which will drastically reduce the permissible time-weighted average (TWA) permissible fiber count and also reduce the permissible ceiling or short term exposure for 15-minute periods. In the Industrial Hygiene Newsletter dated 19Nov75, which went to all works Industrial Hygienists, the possible impact of the proposed changes was reviewed on a paragraph-by-paragraph basis. As stated near the end of that Newsletter, this proposed revision, which may not become final until late 1976, makes it highly desirable for us to replace the use of asbestos and asbestoscontaining materials with non-asbestos material in every situation where the use of asbestos can result in worker exposure to airborne fiber. This, of course, has to be based upon functional suitability of the non-asbestos containing replacement material. This replacement, however, should not be based on strict cost equivalence since the costs of medical surveillance, air sampling and analysis, and training as required by the proposed standard are very considerable. In order to facilitate this conversion, Mr. A. E. Kean of the Pittsburgh Purchasing Department has agreed that Mr. M. J. Caprio of his.group will serve as a clearing house, or contact person, for plant locations seeking alternate non-asbestos materials with satisfactory functional performance. In order for this to be as effective as possible, Mr. Caprio will need to know what physical and chemical properties are required for the application, defined as fully as practicable. As necessary, he will consult with Dr. R. G. LaBar of Alcoa Technical Center for assistance. r< f T' L' According to Mr. J. A. Dunbar of the Ingot, Pigment, Powder and Paste Division, satisfactory non-asbestos alternates have been established for all significant melting and casting applications, except for some applications of Molten Metal Marinite (MMM). Extensive plant evaluation of the alternate material developed for MMM is actively underway. If significant problems are encountered with any of these established alternates, Mr. Dunbar or Dr. LaBar should be made aware of these promptly. j - o, A 412769 0102 sr-4*.s (e i v i--ee` 30Mar76 Page 2 If you have already discovered a satisfactory replacement for asbestos in an application which may be involved at another works location, it would be very helpful if you could make Mr. Caprio aware of enough of the particulars so that he could recommend evaluation of such a material where appropriate in similar situations. Please contact Mr. Robert P. Carter if he can be of any help with respect to whether the proposed asbestos standard would apply to a particular use situation and thereby make seeking an alternate material desirable. ROBERT P. CARTER M. J. CAPRIO MJ C:RPC:lmn Letter to: Industrial Hygienists and District Purchasing Agents Note: Information relative to health standards proposed or promulgated under authority of the U. S. Occupational Safety and Health Act is sent to overseas locations for informational purposes only. cc: Works Physicians Works Engineering Managers and Works Chief Engineers Environmental Health Steering Committee Chairmen & Environmental Managers G. H. Farrah, ATC, Alcoa Center, Pa. Dr. R. G. LaBar, ATC, Alcoa Center, Pa. L. W. Ortlip, EHL, Alcoa Center, Pa. J. M. Plunkett, ATC, Alcoa Center, Pa. Duckworth Daley, Jamaica G. R. Hartnett/Albert Lee - HC Products Co. W. W. Williams, Fort Meade, Florida J. M. Cohen, Pittsburgh 7AB M. 0. Colwell, Pittsburgh 29AB H. W. Cooley/J. Z. Nelson, Pittsburgh 3WPH B. D. Dinman, M.D., Pittsburgh 7AB J. A. Dunbar, Pittsburgh 23AB W. B. Garyotis, Pittsburgh 2AB F.J. McGrath/P.A. Haas, Pittsburgh 20AB A. E. Kean, Pittsburgh 19AB S. I. Roth, Pittsburgh 9AB V. W. Rieke, Pittsburgh 2AB R. H. Watson, Pittsburgh 7AB Copy routed to PRA, GCH, RS 412769 0103 ROBERT P. CARTER HEALTH & ENVIRONMENT DEPARTMENT PITTSBURGH OFFICE, 7 AB TO INDUSTRIAL HYGIENISTS 19Nov75 RE: INDUSTRIAL HYGIENE NEWSLETTER Proposed Revision to OSHA Worker Exposure to Asbestos In the FEDERAL REGISTER for Thursday, October 9, 1975, OSHA published a proposed revision to its standard for worker exposure to asbestos. Regulation 1910.1001. We recommend strongly that all locations obtain a copy of this proposed standard to determine its effect on their operations. If you are unable to obtain a copy of the proposed standard from your subscription to the FEDERAL REGISTER, please contact our office. The proposed standard is found on pages 47652 - 47665 of the October 9, 1975 FEDERAL REGISTER. The Worker Exposure Standard for Asbestos currently in effect which was issued on June 7, 1972, established an 8-hour TWA worker exposure limit of 5 fibers per milliliter of air effective July 7, 1972, with that TWA limit to drop to 2 fibers per milliliter effective July 1, 1976. The new OSHA proposal will change that TWA limit to 0.5 fibers per milliliter, to become effective with the promulgation of the final revised standard. There are many other changes in the proposed standard, the most important of which are covered in the following paragraph-byparagraph analysis of the October 9, 1975 proposal: (a) Scope and application. This section is entirely new. The exclusion of construction work will probably be the only significant effect on Alcoa. However, until a separate asbestos standard for construction is issued, we recommend that the general industry standard be applied to Alcoa construction people. Also, since the definition of construction under Regulation 1910.12 is not clear with respect to its application to our repair and maintenance people, we should apply that standard to their work which provides the greater degree of protection. (b) Definitions. No significant changes. (c) Permissible exposure to airborne concentrations of asbestos fibers. As stated in our introduction, this contains important changes. The standard presently in effect specifies that, as of July 1, 1976, the 8-hour TWA worker exposure drops from 5 fibers per milliliter to 2 fibers per milliliter. The proposed standard would reduce the 8-hour TWA to 0.5 fibers per milliliter. 412769 0104 Industrial Hygienists 19Nov75 Page 2 The present standard calls for a ceiling concentration of 10 fibers per milliliter measured for 15 minutes. The proposed standard would reduce this to 5 fibers per milliliter for a period of "up to 15 minutes (emphasis ours)." Even the preamble or background material published with this standard does not clarify the meaning of the "up to." It is our intention to seek clarification of this so that it can be clearly defined in the final revised standard. As the proposal is presently written, it appears to allow for the interpretation that a worker exposure in excess of 5 fibers per milliliter for any period less than 15 minutes would be considered a violation even if the worker's exposure averaged over the worst 15-minute period did not exceed 5 fibers per milliliter. (d) R6gulated areas. This section is new with "regulated area" being defined as one where a person may be exposed to an airborne asbestos fiber concentration in excess of either the TWA or ceiling limit. A daily roster of all persons entering a regulated area is to be made and retained. (e) Monitoring. This paragraph is expanded and revised. It allows for the selection of representative employees for monitoring to determine the exposures of a particular job occupation group. Area monitoring has been eliminated. If either the TWA or ceiling exposure limit is exceeded, a compliance program and monthly monitoring survey are to be undertaken. If neither exposure limit is exceeded for two surveys at least 5 days apart, but not more than three months apart, no further monitoring is required unless there is reason to believe that an employee's exposure has increased. Each employee is to be notified within 5 working days of the results of tests representing the exposures of his job classification even if another worker was actually monitored. If either exposure limit is exceeded, each affected employee is also to be notified what corrective action is being taken. (f) Method of compliance. Where worker exposures exceed either the TWA or ceiling limit, feasible engineering controls are to be used to reduce the exposures with appropriate respirators being worn until exposures are brought within limits. If needed to meet the exposure limits, work practice controls are also to be used. If airborne fiber levels after the institution of feasible engineering and work practice controls still exceed either exposure limit, respirators must be used to protect the employees. A new provision requires measurements such as capture velocity, duct velocity or static pressure every three months in each exhaust system used for fiber level control to demonstrate continued exhaust effectiveness. 412769 0105 Industrial Hygienists 19Nov75 Page 3 Another new requirement when any employee's exposure exceeds either limit is the establishment and implementation of a detailed written program to reduce the fiber levels within limits "solely by means of engineering and work practice controls." This, to us, implies that control of fiber levels to less than the exposure limits by engineering and work practice controls will always be interpreted by OSHA as feasible. We intend to comment to OSHA on this provision also since, in our judgment, reduction of fiber levels to 0.5 fibers per milliliter may not always be feasible by engineering and work practice controls. (g) Respiratory Protection. This is new as a separate paragraph of the standard and has been expanded from the coverage in the present standard with the only major change for us being in the permissible type of respirator in the fiber range of 10 - 50X the exposure limits. (h) Personal protective clothing. A major change has been made in this paragraph, requiring the providing by the employer daily of clean full-body protective clothing for all employees whose exposures exceed either the ceiling or TWA limit. The present standard requires such clothing only if the ceiling limit is exceeded. (i) Hygiene facilities and practices. This is a new paragraph containing a considerably expanded requirement. The major change involved is the requirement for "clean change rooms" and showers for all workers wearing protective clothing. Another new requirement is that lavatory and toilet facilities located in regulated areas shall not be accessible from uncontaminated areas. The effect of this for us is that, if we have any workers with exposures exceeding either limit, thus requiring wearing of protective clothing, two locker rooms will be required, separated by the showers, with the "contaminated" locker room not to be used by any workers not exposed to asbestos. It would also mean that these employees having excessive exposures would have to be provided separate lavatory and toilet facilities from those used by employees not exposed to asbestos. (j) Medical surveillance. A major change in this requirement provides for informing an employee who refuses a medical examination of the possible health consequences and obtaining a signed statement from him that he has been so informed and refuses to be examined. A serious defect in this proposed revision is that it fails to correct a problem inherent in the present standard; namely, the failure to establish some lower limit of fiber exposure below which medical surveillance will not be required. 412769 0106 Industrial Hygienists 19Nov75 Page 4 Another major change in the medical surveillance is the requirement to obtain from the examining physician a written opinion, a copy of which is to be given to the employee, containing the physician's judgment "as to whether the examined employee has any medical conditions which would place the employee at increased risk of impairment of his health from exposure to asbestos fibers, or which would, directly or indirectly, be aggravated by such exposure." The written opinion also is to contain a physician's recommendation as to any "limitations upon the employee's exposure to asbestos fibers or upon the use of protective clothing and equipment such as respirators." It is also to include a statement that the employee has been informed by the physician of any medical conditions which require further examination or treatment, but with the written opinion not revealing special findings or diagnoses unrelated to occupational exposure to asbestos fibers. The medical surveillance paragraph also stipulates that no employee shall be exposed to asbestos fibers in such a way as would put the employee at increased risk of material impairment of his health from such exposure and that this determination may be based on the physician's written opinion. (k) Employee information and training. This is a new paragraph which requires detailed training for employees assigned to regulated areas including: (1) The nature of operations causing fiber exposures and the necessary protective steps; (2) The engineering controls and work practices associated with the job assignment; (3) Full instructions for appropriate respirators; (4) The purpose for and description of the medical surveillance program; and (5) A review of the standard. Copies of the standard and appendices A, B, and C are to be readily available to these employees. (l) Danger signs and labels. This section was formerly titled "Caution signs and labels." The changes proposed would require the use of the words "Cancer Hazard" to replace "Dust Hazard" on signs for regulated areas and "Danger Cancer Hazard" to replace "Caution - Breathing asbestos dust may cause serious bodily harm" on labels for raw materials and scrap materials. 412769 0107 Industrial Hygienists 19Nov75 Page 5 (m) Housekeeping. This paragraph is essentially unchanged. (n) Recordkeeping. This paragraph has been greatly expanded to require specific details of monitoring tests, employee exposures and rosters, employee training, ventilation measurements, and medical records, with the ventilation measurement and employee training records to be maintained three years and all others for at least 40 years or for the duration of employment plus 20 years, whichever is longer. (o) Observation of monitoring. This is a new paragraph expanding the content of (f)(4) of the present regulation to require the employer to provide the necessary personal protective equipment, where required, for observers and to require explanation of the methods of measurement, including sampling and analysis, as well as allowing the observer to record the results obtained. (p) Appendices. This is a new paragraph which provides the material which is to be used for the training of employees and to be maintained accessible to exposed employees. At this time it is impossible to predict when this revised standard will be promulgated or what it will look like in final form. However, we feel that the likelihood of any major changes from what is proposed is very small. Therefore, the provisions of this proposed revision to the standard and their related cost impact should serve as a further incentive for every location to discontinue the use of asbestos of all forms to the fullest extent functionally feasible even at somewhat higher cost for the replacement material. A major development effort is underway to try to replace completely the use of molten metal marinite in ingot operations with nonasbestos-containing alternates. The complete success of this program for all such applications, particularly the very large ingot sizes, is by no means certain. Your regular monitoring of the marinite cutting operations will be invaluable in establishing whether present practices and control equipment are capable of meeting the proposed 0.5 fiber/ml standard. Another area that probably warrants attention by all locations is that of pipe lagging. The Construction Engineering Division has developed Alcoa Engineering Standards for non-asbestos-containing pipe lagging which are functionally equivalent to asbestos'. These, of course, will now be specified on all major construction projects, but also should be required on all local construction projects and for all repair and maintenance activity. 412769 0108 Industrial Hygienists 19Nov75 Page 6 Shortly after the institution of the asbestos standard in 1972, we recommended that all locations having furnaces of any kind or melting pots in which asbestos had been used as a backing material to any significant extent begin records of the repair and replacement of the linings of these vessels with non-asbestos backing material so that they would know when all of the old asbestos-containing lining had been removed. This was for the purpose of establishing an end point to the necessity of the required provisions of the asbestos standard for the maintenance people involved. These records for any vessels for which this transition has not been completed should certainly be continued till this has been accomplished. If we can be of any help in interpreting the provisions of this proposed standard or any related matter, please do not hesitate to contact us. ROBERT P. CARTER RPC :1ms cc: Company Physicians Environmental Steering Committee Chairmen & Environmental Managers Note: Information relative to health standards proposed or promulgated under authority of the U.S. Occupational Safety and Health Act is sent to overseas locations for informational purposes only. 412769 0109 INDUSTRIAL HYGIENE NEWSLETTER MAILING LIST Arkansas - J. L. Lauderiberg Badin - Earl M. Morgan Chillicothe - J. Schachtele Cleveland - L. L. Grubb Corona - J. W. Mitchell Cressona - C. A. Artz Davenport - K. W. Williams Lafayette - John Castor Lancaster - J. K. Sellers Lebanon - R. Andrew Logans Ferry - W. D. Helmick Marshall - T. N. Wagner Massena - G. D. Hicks COPIES TO: Company Physicians Mobile - W. J. Boutreis Point Comfort - R. E. Podhora Richmond - J. D. Gibbs Rockdale - A. G. Clayton Tennessee - J. C. Vergho Vancouver - L. L. Haisch Vernon - D. P. Hooghkirk Warrick - W. E. Willett Wenatchee - A. B. Plecka Elkem,Farsund,Norway - 0. A. Grytting Fort Wayne, Ind., Rea - Ms. Nancy William Paramaribo, Suriname - A. T. Jondro Point Henry, Geelong - J.H.J.Erkins Sao Paulo, Brazil - M. C. Perry Environmental Health Steering Committee Chairmen & Environmental Managers Alcoa Technical Center- Frank Pessolano Anderson County - L. R. Mathis Arkansas - V. H. Barbour Badin - Wm. H. Freeman Chillicothe - D. L. Berling Cleveland - A. Puleo Cressona - Herbert Rubright Davenport - Emil Stimac Lafayette - J.M.Pickerill Lancaster - T. C. Amend Lebanon - W. M. Klatchko Marshall - Jack Cash Massena - M. J. Elder Mobile - Howard Walker, Jr./ Rhett P. Walker Oslo, Norway - Thorstein Guthe Perth, Australia - L.H.D.Pearcy Point Comfort - M.F.VJones Pt.Henry,Geelong,Australia - Robert Oliphant Richmond - P. W. Blossom Rockdale - Evan Goltra Paramaribo, Suriname - L.E.Olmtak Tennessee - C.L.Kamperman/C.D.Wohlwend Vancouver - W; J. Bovard Vernon - R. R. Suntay Warrick - T. C. Burger Wenatchee - R. T. Bunker Arkansas - J. W. Wells Badin - R. C. Hinkle Chillicothe - J. S. Wood Cleveland - L. J. O'Connell Corona - R. H. Allen Cressona - N. 0. Kraft Davenport - R. J. Reitz Cressona - E. J. Schafer Davenport - J. D. Breazeal Lafayette - H. R. Porter Lancaster - R. S. Howell Logans Ferry - J. Hicks Marshall, Texas - L. E. Norris Massena - R. W. Knapp Mobile - R. V. Newsome Point Comfort - C. L. Green Richmond - G. S. Graves Rockdale - E. B. Parker Tifton - H. E. Chandler Vancouver - D. L. Werner Vernon - J. R. Jones, H. L. Chandler Warrick - R. L. Parsons Wenatchee - J. A. Thompson Copies to: R. P. Carter, Pittsburgh 7 M. 0. Colwell - Pittsburgh 29 J. M. Cohen - Pittsburgh 7 Duckworth Daley - Jamaica B. D. Dinman - Pittsburgh 7 G. H. Farrah - Alcoa Technical Center W. B. Garyotis - Pittsburgh 2 J. M. Plunkett - Alcoa Technical Center V. W. Rieke - Pittsburgh 2 S. I. Roth - Pittsburgh 9 R. H. Watson - Pittsburgh 7 W. W. Williams - Fort Meade, Florida J.Z. Nelson, Pgh_., 3_WPH Copy routed to PRA, GCH, RS G.R.Hartnett/Albert Lee, HC Products Co. 412769 0110 EflflM ROBERT P. CARTER HEALTH & ENVIRONMENT DEPARTMENT PITTSBURGH OFFICE, 7 //-/ /V eTU/ S c T ' July 22, 1975 RE: OSHA ASBESTOS STANDARD - REGULATION 1910.1001 (FORMERLY 1910.93a) At the time when the OSHA permanent standard for worker exposure to asbestos was promulgated in June of 1972, it established an 8-hour, time-weighted average airborne concentration of asbestos fiber of 5 fibers, longer than 5 micrometers, per cubic centimeter of air effective July 7, 1972, with this value to be reduced to 2 fibers per cubic centimeter effective July 1, 1976. There is a good probability that the reduction in permissible employee exposure level to 2 fibers per cubic centimeter will be proposed by OSHA to become effective well before the original date of July 1, 1976. In the light of this situation, all locations making any use of asbestos products, particularly our refining, smelting and ingot locations, should review their situations with respect to their capability of meeting the 2 fiber per cubic centimeter limit by a much earlier date, which could be as soon as December 1, 1975 or January 1, 1976. We believe that it is essential that each location review very carefully the materials which it is presently using for insulation and refractory purposes, including possible uses of asbestos paper and board which can give rise to airborne asbestos fiber. There have been several instances recently where asbestos products have been found to be still in use in such a way that would give detectable airborne fiber concentrations in routine production operations. While the airborne fiber concentration determined at these operations was not excessive, it was measurable and, as such, will require medical examinations for the exposed employees. Of course, all scrap and waste material containing asbestos must be disposed of in accordance with the requirements of the standard. The cost impact of these required medical examinations and the waste material disposal practices may well be such that further effort should be devoted to finding non-asbestos alternates to eliminate the problem altogether. For those ingot locations which are still sawing and machining marinite for headers where there is the expectation of replacing this usage with ceramic headers as outlined in Mr. J. A. Dunbar's letter of June 10, 1975 re "Pilot Production of Ceramic Headers," it appears that there is a good probability that such a change over to ceramic headers will not be completed before any advanced effective date of the two asbestos fiber per milliliter OSHA standard, and perhaps not even by the presently mandated date of July 1, 1976. As soon as sufficient manufacturing and casting experience with ceramic headers has been realized, these locations 0 ALCOA 412769 0111 should develop as definite a program as possible for their complete conversion to ceramic headers, including estimated dates for the completion of the various phases of this change-over. The develop ment of this definite written program can then be used as the basis for the use of appropriate respirators for any workers having asbestos exposures in excess of the two fiber per milliliter limit until the change-over to ceramic headers has been completed and the use of marinite discontinued altogether. At the present time we do not know whether there will be any other changed requirements in the standard than the earlier effective date for the two fiber per cubic centimeter limit. However, if there are any additional or changed provisions, we will advise you of these and their possible impact promptly. ROBERT P. CARTER RPC:1ms ' Letter to: Industrial Hygienists Copies to: Environmental Steering Committee Chairmen cc * V. ff. Rieke, Pittsburgh 2 J. A. Dunbar, Pittsburgh 23 G. R. Swany, Pittsburgh 23 G. H, Farrah, ATC J. M. Plunkett, ATC J. D. Breazeal, Davenport R. H. Watson, Pgh. 7 M. 0. Colwell/B. D. Dinman, Pgh. 412769 0112 Fj?OM ROBERT P. CARTER PITTSBURGH OFFICE TO Tir. Thomas P. Pittsburgh Off! December 23, 3 RE; EMERGENCY STANDARD FOR EXPOSURE TO ASBESTOS DUST In the Federal Register of Tuesday, December 7, 1971, the Occupational Safety and Health Administration, Department of Labor, published a notice of the issuance, effective immediately, of an emergency standard for exposure to asbestos dust. A copy is enclosed for those who have not yet seen it. This emergency standard, which will be effective until further notice, establishes lower permissible employee exposure levels than those which had been made effective with the notification in the Federal Register of Friday, August 13, 1971- We are, therefore, notifying all of our operating locations of this emergency standard so that they may take appropriate cognizance of this with respect to any of their operations involving the handling, cutting, fabricating or other work involving the use of asbestos or asbestos-containing products such as the Marinite which is used extensively in our ingot casting operations. Where there is any question about the present levels of worker exposure v meeting these emergency standards, the use of appropriate respirators should be instituted. Shown on the attachment are all the respirators which have been approved as of February 1, 1971, hy the U.S. Bureau of Mines under their Schedule 21B which is the required type protection as defined in Part 1910.93a, paragraph (c) (2) and (3). A list of approved equipment under Bureau of Mines Schedule 19B as specified in paragraph (4) is also attached. Your attention is also called to paragraph (c) subparagraphs (5) and j(6) which require the establishment of a respirator maintenance program and the proper inspection, cleaning, repairing and storing of respirators. It should also be noted that under paragraph (d) cutting or machining operations such as those which are used at many works for the cutting of Marinite or other asbestos products must be provided with local exhaust ventilation and dust collectors in accordance with American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI Z9.2 - 1971, and also that employees whose exposure results from the spraying of asbestos or the demolition of pipes, structures or equipment covered or insulated with asbestos shall be provided with respirators of the type C positive pressure supplied-air category approved under Bureau of Mines*Schedule 19B. Paragraphs (e), (f) and (g) deal with the mixing of asbestos mbrtar, grout and plaster, the disposal of asbestos waste, and the cleanup of asbestos dust. For your further information, we are attaching a copy of Volume 3, No. 4, Winter, 1971, of the leaflet "Insulations Hygiene Progress Reports'* which contain some very helpful recommendations for minimizing and preventing asbestos dust from becoming airborne in various types of industrial operations. Additional copies of this leaflet may be obtained by contacting directly the source of this publication. 412769 0113 Industrial Hygienists December 23, 1971 Page 2 If you have any questions concerning this important matter, please do not hesitate to contact us. ROBERT P. CARTER RPC:lei TO: INDUSTRIAL HYGIENISTS cc: T. M. Brown, Pittsburgh - 2 E. C. Collins, Pittsburgh - 21 J. W. DeWalt, Pittsburgh - 2 W. B. Garyotis, Pittsburgh - 2 H. J. Goodyear, Pittsburgh - 7 O.P. R. D. Pulver, Pittsburgh - 21 V. W. Rieke, Pittsburgh - 2 H. F. Robey, Jr., Pittsburgh - 21 H. C. Sperry, Pittsburgh - 21 G. H. Farrah, EHL, ATC cc (letter only): Safety Directors (d) 412769 0114 RULES AND REGULATIONS 23207 To be a valid assay, the percent column recovery should be 10O2 percent. () Identity. Proceed as directed In 1141.521 ol thla chapter, using a OS nercent potassium bromide disc prepared as described In paragraph <b) (1> at that ectlon. (7) Crystallinity. Proceed as directed In I 141.604 (a) of this chapter, g 150a.il Minocycline lirdrocltloride capsule*. (a)Requirements tor certification-- } Standards of identity, strength, quality, and purity. Minocycline hydro chloride capsules are composed of mino cycline hydrochloride and one or more suitable and harmless lubricants and dil uents enclosed In a gelatin capsule. Each capsule contains minocycline hydro chloride equivalent to 100 milligrams of minocycline. Its potency Is satisfactory If it is not less than 00 percent and not more than 115 percent of the number of milligrams of minocycline that it is rep resented to contain. Its moisture content Is not more than 12 percent. The mino cycline hydrochloride used conforms to the standards prescribed by 1150g.l(a) (1). (2) Labeling. It shall be labeled in ac cordance with the requirements of i 148.3 of this chapter. (3) Requests for certification: sam ples. In addition to complying with the requirements of f 146.2 of this chapter, each such request shall contain: (1) Results of tests and assays on: (a) The minocycline hydrochloride used in making the batch for potency, safety, moisture, pH. minocycline con tent, Identity, and crystallinity. (b) The batch for potency and moisture. (U) Samples required: <a> The minocycline hydrochloride used in making the batch: 10 packages, each containing approximately 300 milligrams. (b> The batch: A minimum of 30 capsules. <b) Tests and methods of assay--Cl) Potency. Proceed as directed in 1141.111 of this chapter, preparing the sample for assay as follows: Place a representa tive number of capsules Into a high-speed glass blender Jar with sufficient 0.1W hydrochloric acid to give a stock solution of convenient concentration containing not less than 150 micrograms of mino cycline per milliliter (estimated). Blend for 3 to 5 minutes. Remove an aliquot and further dilute with 0.1M potassium phosphate bufler, pH 4A (solution 4), to the reference concentration of 0.100 microgram of minocycline per milliliter (estimated). (2) Moisture. Proceed as directed In I 141.502 of this chapter. Data supplied by the manufacturer concerning the subject antibiotic have been evaluated. Since the conditions pre requisite to providing for its certification have been complied with and since not delaying in so providing Is in the public Interest, notice and public procedure anl delayed effective date are not prerequi sites to this promulgation. Effective date. This order shall be ef fective upon publication in the Federal Registei (12-7-71). (See. 607, 69 Stat. 4S3, u amended; 21 0.S.C. 387) Dated: November 21, 1971.. H. E. Simmons, Director, Bureau of Drugs. (FB Doc.71-17773 Filed 12-3-71.8:45 am] Title 29--LABOR Chapter XIII--Bureau of Labor Standards, Department of Labor PART 1518--SAFETY AND HEALTH REGULATIONS FOR CONSTRUCTION Standard for Exposure to Asbestos Dust Pursuant to section 4(b) (2) of the WUliams-Steiger Occupational Safety and Health Act of 1970 (84 Stat. 1592, 29 UJS.C. 653). { 1518.55 of Title 29, Code of Federal Regulations, Is hereby amended in the manner indicated be low In order to prescribe a new stand ard limiting the exposure of workers to asbestos dust. The new standard limit ing the exposure of employees to asbes tos dust Is that adopted under section 6(c) of the Williams-Steiger Occupa tional Safety and Health Act of 1970 and published in the Federal Recistx* on this date. The standard Is hereby de termined to be more effective than that presently provided under 11518.55 to the extent that It prescribes minimum levels of exposure to asbestos dust. Therefore, by operation of section 4(b) (2) of the Act the new standard Issued under section 6(c) supersedes the con struction safety standard relating to ex posure to asbestos dust. Section 1518.55 is hereby amended by adding a new paragraph (c) thereto. As amended 11518.55 reads as follows: S 1518.55 Cues, vapors, fames, dusts, and mists, * (c) Paragraphs (a) and (b> of this sec tion do not apply to the exposure of em ployees to airborne asbestos dust. When ever any employee is exposed to airborne asbestos dust, the requirements of I 1910.93a of this title shall apply. Effective date. This amendment shall become effective upon publication In the Federal Register (12-7-71). (Sac. 4(b)(2), 84 Stat. 1692. 29 UJS.C. 653; Secretary's Order No. 12-71,38 PR. 8754) Signed at Washington. D.C,, this 2d day of December 1971. Q. C. Guenther, Assistant Secretary of Labor. |FR Doc.71-17835 Filed 12-3-71:8:47am] Chapter XVII--Occupational Safety and Health Administration, De partment of Labor PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Emergency Standard for Exposure to Asbestos Dust Pursuant to section 6(c) of the Williams-Steiger Occupational Safety and Health Act of 1970 (84 Stat. 1596. 29 U.S.C. 655), Part 1910 of Title 29. Code of Federal Regulations (36 F.K. 10466, May 29, 1971) Is hereby amended In the manner Indicated below In order to pro vide an emergency standard dealing with the exposure of employees to asbestos dust. In light of Increasing Information on the results of exposure of employees to airborne asbestos dust. Including recent studies by the National Institute for Oc cupational Safety and Health and others, and recommendations by the American Conference of Governmental Industrial Hygienists (ACGIH). It is hereby deter mined that (1) exposure under the pres ent standard for asbestos dust in Table G-3, f 1910.93, of 12 fibers per milliliter greater than 5 microns in length or 2 million particles per cubic foot of air. which is derived from an established Fed eral standard promulgated under the Walsh-Healey Public Contracts Act on May 20, 1969, constitutes a grave danger to employees exposed to this 8-hour time-weighted average concentration; and that (2) an emergency standard Is necessary to protect employees from this excessive exposure. The National Insti tute for Occupational Safety and Health concurs that the proposed change In the asbestos dust standard recommended by the American Conference of Governmen tal Industrial Hygienists should be the substantial base for the emergency standard. Action concerning the standard will be commenced under section 8(b) In the Immediate future. -Any . notice of pro posed rulemaking under section 6(b) will give notice of the emergency standard as a proposed rule and also of any ap propriate subsidiary proposals which may be required under subparagraphs (5) and (7) of section 6(b) relating to the ex posure of employees to toxic substances. Part 1910 is amended as follows: 1. Table G-3 following i 1910.93 (36 PH 15104. Aug. 13, 1971) Is hereby amended by deleting the following: Aabestoe--12 flben per milliliter greater than B microns m length or2 Upper. Tremotlte6 Mppcf. 30mgyU* "^sTbT' _ ___ _ JIOl 23S '-"f KOEtAl RfCISTU. VOL 35, NO. 134--TUESDAY, 0ECEM1EC 7, 1*71 412769 0115 2.1208' RULES AND REGULATIONS i aj amended. Table 0-3 reads as follows: Tails 0-3--NinwuDWTM Mppc/ M/M* SiCllerrr*lAUitline: (JUAfU (iw?plf*b),,. * Quart* (total dUSl). CrfrtobaUU: Uw M lb* eatae calctileurt from th oouoi or mass formulae lor TrSrSte: f H the t*Iw calculated firom the fornmiM for quart*. Amorphous, loclodlof natural dialomactous rarth............... . 250 I IOzdc/M* %8fOH-2 tOmc/M* 7.S.0H-2 aOmg/M* TcSlOt Ciikattf (less than 1% err** talllos dlfca): Him......................................... TWf __' 6opMU................................ 20 Portland OAZneBt.................... 50 Graphite (mtanX),...... .......... U Coal dost (Teeptrabfc traction km lhan*% BiO)...................................... 7or more than 4% fllOi................................. 2.4mc/M* or 10mg/Mi Inert or Nob*OM Dost: Reeptrabk fraction..18 Total dost.__ ............. %SiO,+2 Smc/M' 16mg/M* Non: CoDTtnfos laetora-- mppcfXM.*-million particles per cubic meter particke per c.c. IfUUoos of particles per coble foot of air, based on fanptafer samples coasted by lltfit-fleld technics. i Th* perceaUce of crystalline silica is the formula Is the amooot determined from atr-bome samples, ex cept to those instances to which other methods h are been shown to be applicable. i As determined by the membrane filter method at OOXpfcase contrast magnification. Both oooeentration and percent quarts for the appli cation of this Umlt ara to be determined from the fraction peeing a else selector with the following characteristics: Aerodynamic diameter (unit density sphere) Percent passing selector 2.8 r: 18 6.0 IQ 00 75 80 25 0 The measurements aOder this note refer to (he ase of an AEC Instrument. If the respirable fraction of coal dost Is determined with a MBE the figure corresponding to that of 2.4 Mg/M* in the table for ooai dust is 4A Mg/M, 2. A new 5 1910.93a Is added to Part 1910. The new } 1910.93a reads as follows: 1910.93a Aabestoa dust. (a) The 8-hour time-weighted aver age airborne concentration of asbestos dust to which employees are exposed shall not exceed 5 fibers per milliliter greater than 5 microns In length, as de termined by the membrance filter method at 400-450 x magnification (4 millimeter objective) phase contrast illumination. Concentrations above 5 fibers per milliliter but, not to exceed 10 fibers per milliliter, may be permitted up to a total of 15 minutes In an hour for up to 5 hours In an 8-hour day. (b> Engineering methods, such as but not limited to, enclosure, vacuum sweep ing, and local exhaust ventilation, shall be used to meet the exposure limits pre scribed in paragraph (a) of this section. Where such engineering methods are not feasible, or do not otherwise reduce the concentrations below those prescribed In paragraph (a) of this section, respira tory protective devices shall be provided and used In accordance with paragraph (c) of this section. (c)(1) (1) When the limits of ex posure to asbestos dust prescribed In paragraph (a) of this section are ex ceeded and when engineering controls required by paragraph (b) of this section are not feasible or do not otherwise re duce the concentration of asbestos dust below those prescribed in paragraph (a) of this section, the employer shall re quire the use of respiratory protective de vices. The selection of respiratory protective devices shall be limited to those specified in the remaining subparagraphs of this paragraph (c). (11) The employer shall require that each employee test his respiratory pro tective device before each use in order to insure a proper fit according to the manufacturer's instructions. The em ployer shall further provide for effective training or supervision of employees In the testing of respiratory protective de vices for fit before their use. (2) For an atmosphere containing not more than 25 fibers per milliliter greater than S microns In length over an 8-hour average, or more than 50 fibers per milli liter over any period of 15 minutes, a reusable or single-use filter type respira tor, operating with negative pressure during the inhalation phase of breathing, approved by the UJ5. Bureau of Mines under the provisions of 30 CFR Part 14 (Bureau of Mines Schedule 21B), or a valveless respirator providing equivalent protection, shall be used. (3) For an atmosphere containing not more than 250 fibers per mlllilter greater than 5 microns in length over an 8-hour average, or more than 500 fibers per milliliter over any period of 15 minutes, a powered filter positive pressure res pirator approved by the 1JB. Bureau of Mines under the provisions of 30 CFR Part 14 (Bureau of Mines Schedule 21B) shall be used. (4) For an atmosphere containing more than 250 fibers per milliliter greater than 5 microns In length over an 8-hour average a type C positive pres sure suppUed-air respirator approved by the 08. Bureau of Mines under the pro visions of 30 CFR Part 12 (Bureau of Mines Schedule 19B) shall be used. (5) The employer shall establish a respirator program in accordance with the requirements of American National Standard Practice for Respiratory Pro tection Z88.2--1989. (6) The respirators provided each em ployee shall be properly Inspected, cleaned, repaired and stored. (d) (1) When an employer has em ployees who are exposed to asbestos dust exceeding the limits prescribed In para graph (a) of this section and the ex posure results from the operations de scribed In the remaining subparagraphs of this paragraph (d>, the employer shall comply with the requirements of these subparagraphs relating to the operations involved. The requirements of this para graph are In addition to those prescribed In paragraph (b) of this section. (2) All hand- or power-operated tools which produce asbestos dust such as, but not limited to. saws, scorers, abrasive wheels, and drills shall be provided with local exhaust ventilation and dust col lectors In accordance with the American National Standard Fundamentals Gov erning the Design and Operation of Local Exhaust Systems; ANSI Z9.2--1971. (3) Employees exposed to the spraying of asbestos or the demolition of pipes, structures, or equipment covered or In sulated with asbestos shall be provided with respiratory protective devices in accordance with paragraph (c) (4) of this section. (e) Asbestos cement, mortar, coatings, grout, and plaster shall be mixed in closed bags or other containers. (f) Asbestos waste and scrap shall be collected and disposed of In sealed bags or other containers. (g) All cleanup of asbestos dust and blowing shall be performed by vacuum cleaners. No dry sweeping shall be per formed. 3. Section 1910.12 Is amended by changing paragraph (a) In order to apply the emergency standard prescribed In the new { 1910.93a. which is published in this document, to construction work which is subject to the Act. The amendment is necessary In light of the rule of regula tory construction set forth In { 1910.5(c). As amended, { 1910.12 reads as follows: 1910.12 Construction vrorfc. (a)(1) Adaption and extension of es tablished safety and health standards for construction. The standards pre scribed by Part 1518 of this title and in effect on April 28. 1971, are adopted as occupational safety or health standards under section 6(a) of the Act and shall apply, according to the provisions thereof, to every employment and place of employment of every employee en gaged In construction work. Each em ployer shall protect the employment and places of employment of each of his employees engaged in construction work by complying with the appropriate standards prescribed by this paragraph. (2) Hie standards prescribed in I 1518.55(c) of this title shall apply In the case of the exposure of any em ployee In construction work to airborne asbestos dust. * Effective date. These amendments shall become effective immediately upon publication In the Federal Register (12-7-71). (Sec. (c). 84 8tat. 1696, 29 T7.S.C. 655; Sec retary's Order Ho. 13-71, S6 PJt. 8764) Signed at Washington, D.C., this 2d day of December 1971. G. C. Guenther. Assistant Secretary of Labor. int Doc.71-17883 Filed 13-6-71:8:47 ami \ 0 ;! i* .< FEDERAL REGISTER, VOL. 36, NO. 234--TUESDAY, DECEMBER 7. 171 412769 0116 Environmental Scioncoo Laboratory wtj/a, of Tho City Untwrmlty of Now York INSULATION HYGIENE PROGRESS REPORTS FROM THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM Irvine Solikoff. M.D., Procram Director Vot 3, No. 4 Wlntar 1971 Dust produced by use of an unventi lated band saw. Without the back light ing used here, much of the dust would not be visible. Cutting pipe with band saw equipped with high-velocity, low-volume exhaust system. Compare absence of any air borne dust with that shown in uncon trolled cutting (picture left) --Shipyard Procedures Guide- Helps All Insulation Men The Winter 1970 issue of Insulation Hygiene Progress Re ports announced a joint effort by the Insulation Industry Hygiene Research Program, the U.S. Navy, the Department of Labor, and insulation manufacturers and contractors to control shipyard asbestos dust exposures. As part of that effort, Duncan A. Holaday and William B. Reitze of the IIHRP prepared a procedures guide for shipyard insulation application and removal. Because of its relevance to all insulation work, portions of it are given in this issue of Insulation Hygiene Progress Reports. A complete report was presented by the authors at* the Inter national Symposium on Safety and Health in Shipbuilding and Ship Repairing, at Helsinki, Finland, on August 30, 1971. by Duncan A. Holaday and William B. Reitze The general goal in all insulation work should be to maintain a clean environment. Measurements of concentrations of asbestos fibers ("dust counts") in the atmosphere can be used to identify sources of contamination and to point out deficiencies in control methods. Primary reliance for control of ex posures, however, must be placed on faithful observance of operating rules. Control of Asbestos-Containing Dusts by Use of Substitute Materials Substitution of materials contain ing reduced proportions of asbestos or no asbestos at all, is becoming more common in ship construction. Before a material is substituted for asbestos, however, two questions must be carefully considered: a. Has the substitute material been tested? If not, it may turn out to be of the same or greater hazard than the material of known haz ard. This sort of thing has hap- Here Are Some of Many Ways to Reduce Dust pened in other environmental situations. b. Does the new material meet engi neering specifications and will it perform adequately under condi tions of use? Materials containing reduced amounts of asbestos have been used in the fol lowing applications: a. Blanket and pad filling Substitution of the proper types of other pad fillers not only re duces asbestos dust during fabri cation and installation but also tends to lessen the problems dur ing subsequent "rip-out". Addi tionally, asbestos cloth which has been treated with a dust suppres sant is available and its use should also be encouraged. There are re ports that much less dust will be produced. b. Pipe covering and block Serious consideration should be given to those products contain ing lower amounts of asbestos fiber. Several British firms have introduced asbestos-free calcium silicate block and pipe covering. To date, however, this material has not been adequately evaluated in the United States to determine how it will perform in use. Reduction of Dust by Changes in Work Methods a. Mixing Asbestos Mortar This operation has- usually been done at the job site. While the time spent in mixing is quite short, considerable dust is pro duced. A tested method of control is to mix the mortar dockside under controlled conditions and package the mixed mortar in sev eral containers for transportation to the job site. Mortar is also available packaged (Continued on second page) 412769 0117 Insulation Hygiene - Progress Reports Vol. J. No. 4 Winter 1971 Procedures Used at Puget Sound Naval Shipyard from the Insulation Industry Hygiene Re search Program Editor! W. J. Nicholson, Ph.D., Published at the Environmental Sciences Laboratory (Irving J. Selikoff, M.D., Director), 'Mount Sinai School of Medicine of the City Uni versity of New York, New York, N.Y. 10029 Advisory Council of IIHRP Irving J. Selikoff, M.D. Program Director and Chairman EL Cuyler Hammond, Sc.D., Vice President, American Cancer Society, New York, N.Y. Albert Hutchinson, General President, International Association of Heat and Frost Insulators and Asbestos Workers, Washington, D.C. Fred L. Pundsack, Ph.D. Vice Presi dent, Research and Development, Johns-Manville Corporation, New York, N.Y. PURPOSES OF THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM (Continued from first page) in several sizes of plastic bags which have a spout through which water is introduced. Sufficient wa ter is added to moisten the mor tar; after premixing, the bag is opened and the remaining water added. The carton in which the bag is packaged may serve as a mixing box and waste container. 6. Pre-cutting pipe covering and block in the fabrication shop Hand-cutting of pipe covering and block should be kept to an absolute minimum. Bend sections, pipe cover lengths, and blocks, should be cut in the fabrication shop on exhaust-ventilated equip ment. How the Navy Does It * At the Puget Sound Naval Ship yard, cut sections are dipped in water and then packed in plastic bags which are labeled to identify the location where they are to be used. The cut sections are still damp and relatively dust-free when they are applied and the plastic bags are available for use in collecting wastes. c. Pre-scoring blocks Insulation blocks should not be scored at the job site. Blocks which have been pre-scored by the manufacturer can be pur chased, or standard blocks can be scored in the fabrication shop by using an exhaust-ventilated ga-ig saw. d. Insulating pipe assemblies in the shop Some pipe assemblies are quite intricate and are troublesome to lag while in place. A satisfactory method of doing these jobs, par ticularly during ship repair, which is employed by the Puget Sound Naval Shipyard, is to re move the assembly in conveniently sized sections and transport them to the shop. Here the old insula tion is removed, any necessary repair of the pipes performed, and the assembled section re lagged. Relag in the Shop Not only is dust dispersion re duced, but it is much more con venient to re-lag the section in the shop than when it is in place shipboard. Any insulation which is damaged during transport and fitting is repaired after the sec tions are in place. e. Hand-cutting at job sites Some hand-cutting at job files is unavoidable. However, dispersion of dusts by these operations can be minimized. A portable downdraft table is used by the Puget Sound Naval Shipyard. This table has folding legs so that it can be carried down companionways and set up conveniently to the work. A small industrial vacuum cleaner is the source of exhaust. Scrap is dropped into a plastic bag and a (Continued on third page) 1. To develop improved methods for minimizing ex posure of insulation workers to dusts and fumes encoun tered in their work. 2. To disseminate knowl edge of these improved methods of dust control wherever they may be ap plied advantageously and to offer cooperation, advice and assistance toward their universal adoption. . High temperature mortar packed in plastic bag. Water is added to bag through spout and mortar moistened before opening. The moistened mortar is removed as required and mixing completed in shipping container. All wastes are placed in container and sent to disposal at end of shift Procedure used at Puget Sound Naval Shipyard for handling bend sections. Sections are cut in fabrication shop, dipped in water and placed in plastic bag. The bag is then labelled with the job-site description. 412769 0118 Dampening fibrous glass blanket filler before cutting. Note lateral draft hood in-which fabrication is done. (Continued from second page) dropcloth is placed on the deck under the equipment /. Fabrication of Pads and Blan kets Pads for valves and machinery should be fabricated in the shop whenever possible. Amosite has been largely replaced by fibrous glass filling with covers of an asbestos cloth which has been treated with dust suppressants. As an effective means for suppressing dust dispersion and collection, the fibrous glass blanket is unrolled, dampened and rerolled. This pro cedure insures that all the blanket will be dampened. The blanket and asbestos cloth shapes are cut in the lateral draft booth. g. Housekeeping and Clean-up Essential parts of a dust control program are housekeeping and clean-up procedures. Meticulous attention must be given to re stricting the spread of dust and larger wastes. Use of a dropcloth under a work area vividly illus trates how much waste would be distributed over the general area or to lower decks if one were not used. Areas should be cleaned up at the lunch break and the end of each shift, using an industrial vacuum cleaner to collect dust and small scrap. In all possible instances, work men should clean up their own areas. Where work rules prohibit this, the clean-up crew should be under the direction and super vision of the insulation foreman to insure that proper attention is given to this important subject. Reduction of Dusts by Use of Local Exhaust Ventilation i. Ventilation of Large Power Tools--Band Saws Extensive use of band saws both in dockside fabrication, shops and, on board larger ships such as aircraft carriers make emissions from band saws a major source of asbestos dust Control devices for such saws have been known for years and are relatively sim ple. Conventional low-velocity, high-volume systems, using a negative pressure baghouse for air cleaning, are practical in a fixed installation fabrication shop. Because some degree of porta bility is desirable in a temporary shipboard fabrication area, a high-velocity, low-volume dust collection unit is desirable for Portable down-draft table developed by Puget Sound Naval Shipyard for use shipboard. Lightweight industrial vac uum cleaner is used as the air mover. Note plastic bag for scrap and dropcloth on deck. such use; it may also be suitable for fixed installations. The air mover is an industrial vacuum cleaner which pulls about SO cubic feet of air per minute past the saw blade at velocity of more than 10,000 feet per minute. This system is a very efficient dust col lector. Units such as this can also be designed to control dusts pro duced by table saws and gang saws. b. Ventilation of Hand Power Tools High-velocity, low-volume collec tion systems control dust emis sions from most small power tools adequately. Saber saws for cut ting pipe covering and rotary saws for cutting asbestos cement board are well controlled with these systems. Control of Number of Workmen Exposed a. Scheduling of Insulation Work Standard industrial hygiene prac tices call for insolating operations which contaminate the atmosphere with toxic materials. Areas where insulation work is being done under conditions in which dust might be created should be iso lated by non-flammable curtains or other means. Whenever possible, work should be scheduled to minimize the numbers of other tradesmen in the area. Ship con struction operations are more readily scheduled than are ship repair or ship-breaking jobs. However, every effort should be made to keep the number of men exposed at a minimum. In par ticular, rip-out of old insulation should always be isolated and, if necessary, performed on an offshift Trained workmen supplied with proper protective equipment should always be used for rip-out work and it should be scheduled for rapid completion. Personal Protective Equipment In addition to dust suppression and dust control procedures, personal pro tective equipment is often necessary to reduce exposure and limit the spread of contamination. The equip ment described below is used in con trol programs. a. Protective Clothing Protective clothing is required to keep contamination confined to the work areas. One method is to issue disposable coveralls which can be removed when leaving the (Continued on fourth page) Use of dropcloth to contain wastes and facilitate clean-up. 412769 0119 A small industrial vacuum cleaner being used by a Local 62 asbestos worker for clean-up. (Continued from third page) work area or some time prior to entering the locker room and - placed in plastic bags for disposal. Resin Impregnated Paper A satisfactory type of protective clothing consists of resin impreg nated paper coveralls. These are inexpensive and readily disposa ble. They prevent spreading con tamination to laundries and elimi nate pilferage. They are worn for one shift, then removed and placed in plastic bags for disposal with other asbestos-containing wastes. 6. Respiratory Protective Equip ment Occasionally some operations gen erate so much dust that it is virtually impossible to maintain satisfactory atmospheric concen trations of asbestos fibers and respiratory protection must be provided to the workers. A variety of respiratory protective equip ment is available from which devices suitable for various situa tions can be selected. American National Standard Z88.3-1971, Safety Guide for Respiratory Pro tection Against Asbestos-Contain ing Dusts (obtainable from Amer ican National Standards Institute, 1430 Broadway, New York, N.Y. 10018) should be referred to for detailed information. Invisible Dust It is emphasized that unsatisfac tory amounts of respirable dust can be present in the air even though conditions are not visibly dusty. I. Air-supplied Respirators Extremely dusty jobs, such as ripout of old insulation where dust concentrations are very high, re quire use of air-supplied respi rators which will deliver clean, dust-free air to a facepiece or hood. Two general types are available: air-line and self- Saber saw equipped with high-velocity, low-volume exhaust system. powered. a) Air-line respirators in which air is supplied to a hood, helmet or facepiece give the greatest de gree of protection. Air is fed to the facepiece from a compressed air-line. The air source must be located in an uncontaminated area and if the source is not specifically designed for breathing purposes, a temperature sensing alarm must be installed on the compressor or a carbon mon oxide monitoring device must be installed in the air-line. Disposable Hood Anti-freeze compounds should not be used in the compressor system; water vapor must be removed by dessicant and oil mists removed by a filter. A plastic, disposable hood has been developed by the Puget Sound Naval Shipyard for situ ations where a very high degree of protection is required. This hood and other similar ones are available commercially. The air line should be fastened to the hood with a quick-disconnect fitting. Self-powered Respirators b) Air-line respirators connected to a compressed air supply limit movement, and this limitation can be troublesome. Self-powered res pirators do not impose such limi tations, but they do add to the equipment the workman must carry and they also require care ful maintenance. 2. Particulate-filtering Respira tors There are several types of par ticulate-filtering respirators. Those with a half-mask facepiece are considered most suitable for use by insulators. Only those ap proved for protection against as bestos dust by the U. S. Bureau of Mines should be used. These devices are recommended for use in situations where the atmos pheric concentration of asbestos fibers is at relatively low levels. All the recommendations for res pirator-fitting, training of work men and maintenance, detailed in Z88-3-1971 should be followed. a) Reusable particula.'e-filtering respirators A variety of reusable particulatefiltering respirators are available. To insure proper fitting, several different makes should be avail able from which the workman can select one. No one model respira tor facepiece will fit all faces. Routine maintenance is absolutely necessary to replace clogged filters and leaking inhalation or exhala tion valves. Unmaintained res pirators produce a false sense of security. Maintenance Troublesome b) Disposable particulate-filter ing respirators Operation of an adequate respira tor maintenance program can be troublesome and, if only a few men are involved, impractical. Disposable respirators are avail able which are designed to be worn for no longer than one shift and then discarded. Education and Training No dust control program can be effec tive unless workmen and supervisors understand the hazards associated with the jobs, the sources of the hazards and the reasons for following recommended procedures carefully. Understanding is only obtained by education of personnel and training in correct operating procedures. For an education and training program to be successful, both management and labor must be concerned and partici pate. As with all safety programs, it is essential that first-line supervisors be interested in and cooperate in the work. The harmful effects of neglect of pro cedures for controlling asbestos dust are not apparent for many years. Therefore, it is more difficult to con vince workmen and supervisors of the necessity of following rules for working with insulating materials than if more obvious physical haz ards were involved. Education in hazards associated with use of insulating materials and in struction in correct work practices should be included in apprentice training programs. PHOTO CREDITS: Pg. 1, I.I.H.R.P.; pg. 2, Ryder Industries and Puget Sound Naval Shipyards (P.S.N.S.); p. 3, P.S.N.S.; pg. 4, I.I.H.R.P. and P.S.N.S. 412769 0120 FROM MICHAEL J. VAUDREUIL PITTSBURGH OFFICE lSl i&L | iVtoP^'3. Dr. B. D.^DInman Pittsburgh Office - 6 INDUSTRIAL HYGIENE CONTACTS DOMESTIC & FOREIGN 1980 August 14 RE: ASBESTOS REPLACEMENT PROGRAM As part of Alcoa's asbestos replacement program, a listing of applications and substitutes for asbestos was compiled and distributed in August of 1979. Since that time, some headway has been made in the development of substitutes for several uses of asbestos. The progress to date is reviewed in the attached memorandum. An updated version of the original master listing is in preparation. Distribution of the revised registry is planned for 1980 November 01. However, critical to this effort is additional input from all Alcoa locations. Information on current plant asbestos use, as well as any successes (or failures) with substitute materials is requested. In order to meet the November 01 target date for release of the updated list, replies should be received by 1980 October 01. This ongoing exchange of information is necessary for the continued success of the program. With the assignment of Haig Sakoian as Senior Industrial Hygienist, Tennessee Operations, I have assumed the responsibility for overall coordination of the asbestos replacement program. Therefore, please direct all future correspondence to my attention. MICHAEL J. VAUDREUIL MJV:mlf Distribution: Location Managers - Domestic & Caribbean Location Managers - Subsidiaries & Allied Products Safety Managers - Domestic & Caribbean Safety Managers - Subsidiaries & Allied Products Location Engineering Managers Purchasing Agents J. H. Sloane - Pgh. K. W. Perry - Pgh. R. W. Wrenn - Pgh. T. W. Callaham - ATC T. J. Sherman - Pgh. E. B. Perry L. C. Drapela R. N. Sater F. J. McGrath R. C. McCormack - Pgh. - Pgh. - Pgh. - Pgh. - Pgh. T. I. Stephenson 0 G- F- ALCOA - Pgh. - Pgh. 412769 0121 FROM MICHAEL J. VAUDREUIL PITTSBURGH OFFICE TO MEMORANDUM 1980 August 14 RE: ASBESTOS REPLACEMENT UPDATE The following sections summarize the progress made over the past year in the search for asbestos substitute materials. The discussions are organized by asbestos product, and within each section by specific application. A supplemental list of substitute material suppliers is included. 1. Molten Metal Marinite There is presently only one necessary use for asbestos in ingot plant operations; that is, header applications. There are adequate replacements in Johns-Manville's Marinite I and Pyrotek*1s2 3Pyrotherm B-2 board products and R-680 for all other melting and casting needs. Therefore, Molten Metal Marinite need not, and should not be used for dams, basins, troughs, etc. However, at present, the suitability of substitute materials for use as floats is questionable. Some header-related applications of asbestos have also been eliminated. After header design modifications, R-680 can be used for all FDC headers 635 mm (25 in.) and smaller. With this substitution, Lafayette, Vancouver and Massena should be asbestos free. Molten Metal Marinite must still be used for HDC and tool and jig headers. R&D programs at ATC will continue to address these areas. 2. Asbestos Rope Fiberseal A-l rope (Pyrotek, Inc.) can be used in place of asbestos rope for sealing the gap between the mold and bottom block in FDC casting operations. It prevents metal leakage and its good thermal stability allows it to be reused numerous times. It may also be used for sealing joints in pouring troughs. Z-5 treated fiberglass rope (Pyrotek, Inc.) can be used successfully as a crucible lid gasket on vacuum-type potroom tapping crucibles. It replaces the presently used Johns-Manville 872 or 702 asbestos gasketing material. However, Z-5 will not replace gaskets made of twisted aluminum foil. Plants using foil gaskets will in all probability have to continue that practice. 3. Transite Transite, a structural, fire-retardant asbestos/portland cement board, is used extensively in construction. ATC has tested glass-reinforced cement (GRC) sheet as a replacement for transite. E3 ALCOA 412769 0123 SUPPLEMENTAL SUPPLIER LIST Product TM Nextel 312 (ceramic fiber) Z,, etex TM (a.k.a. Pyrotex ; Thermog.lass TM (fiberglass) HI FibeR (coated polyethylene fibers) Celiox Fibers (polyacrylonitrile) *heat treatment Available Forms Supplier Phone No. 1. woven fabric Ceramic Fiber and tape Products/3M 2. braided sleeving 219-1 3M Center 3. bulk fiber St. Paul, MN 55101 612/733-1558 1. woven fabric Newtex Industries Railroad Avenue P. 0. Box 25 Victor, NY 14564 716/924-9135 1. twisted rope Amatex Corp. 2. braided sleeving 1032 Stanbridge St. 3. woven fabric Norristown, PA 19404 and tape 215/277-6100 1. fiber fillers for cement, caulkings, etc. Hill Bros. Chemical Co. One City Boulevard Suite 1521 Orange, CA 92668 714/634-3322 1. fabrics *2. conversion to pure carbon fibers Celanese Plastics & Specialities Co. 26 Main Street Chatham, NY 07928 201/635-2600 CER-WOOL (ceramic fiber) 1. blankets 2. vacuum-formed boards 3. bulk fiber C. E. Refractories P. 0. Box 828 Valley Forge, PA 19482 412/351-4409 Siltemp (fibrous glass) 1. cloth GRC Sheet (fiberglass reinforced cement) 1. flat and corrugated board Haveg Industries, Inc. 900 Greenback Road Wilmington, DE 19808 GRC Products, Inc. 17051 I.H. 35N Schertz, TX 78154 1-800-441-7777 512/651-6773 GRC Sheet (fiberglass reinforced cement) 1. flat and corrugated board CEM-FIL Corporation 120 Spence Lane Nashville, TN 37210 615/883-7563 ,, TM Preox 1. woven fabric (polyacrylonitrile fiber) Gentex Corporation Carbondale, PA 18407 717/282-3550 TM Kelvar ^ and Nomex (aramid fiber) 1. cloth E.I. duPont de Nemours 302/999-4693 2. rope & Co. 3. pump packings Textile Fibers Department 4. tapes and Wilmington, DE 19898 webbings 5. braided sleeving MICHAEL J. VAUDREUIL:mlf 80-08-05 412769 0125 Product Bulletin Thermocouple Insulation At last: a practical high-temperature insulating material that eliminates the two biggest causes of thermocouple failure. Dimensional stability and abrasion resis tance have always been big sources of trouble for high-temperature insulators. The most commonly used fibers- those made from vitreous silica typically shnnk. abrade, fray, or crumble to the point where wires become exposed This obviously creates a potential for inaccurate tempera ture readings. The traditional alternative, ceramic beads, solves the problem of ex cessive shrinkage and abrasion but only at a high cost for labor. Now there's a better alternative. Nextel" 312 Ceramic Fiber from 3M Nextel 312 withstands operating temperatures of 1000 F. to 2600 F continuously. It shrinks less and resists the combined effects of abrasion, flexing, and high temperatures better than asbestos, quartz, and vitreous silica fibers. It also offers good chemical resistance and immunity to thermal shock. Proven dimensional stability. A recent test compared the dimensional stability of Nextel 312 and vitreous silica by heating sleeves braided around separate lengths of wire for v2 hour at 2000 F When the samples were removed from the furnace. Nextel 312 still covered the wire completely, thanks to shrinkage of less than 1 per cent. The vitreous silica fiber had shrunken by roughly 12 per cent, leavmg an inch of wire exposed at one end. Exceptional resistance to abrasion, In another test, a Duplan silk-testing ma- chine-" was used to compare filaments of Nextel 312 and vitreous silica. Blades were rubbed back and forth on the two products after they had been heated for 'h hour at 1000 F.. 1500 F. and 2000 F. Results showed that Nextel 312 lasted 2'/2 to 5 times as long as the vitreous silica fiber This means that at 1000 F Nextel 312 performed 400 per cent better. The figures for 1500 F. and 2000 F. were 300 per cent and 166 percent respectively. No residual acids or chlorides to cause etching of wires. Because Nextel 312 Ceramic Fibers con tain no residual acids or chlorides, there's no chemical present to corrode or etch the wires. Even in a test involving exposure to 96 per cent relative humidity, no notice able electrolytic corrosion was detected. The test consisted of putting Nextel 312 fibers in contact with two unconnected bare #32 copper wires A 250-volt D.C. po tential was applied across the wires. After 20 hours, corrosion was determined by calculating the ratio of anode wire tensile slrength to cathode wire tensile strength. Three test runs produced ratios above 0.99: since the maximum ratio possible was 1.00. there was essentially no elec trolytic corrosion Available from your local thermocouple supplier. Nextel 312 is being manufactured in pro duction quantities right now. For more information on how it can increase the ser vice life of your thermocouples, contact your supplier Or call 3M at 612-733-1558 (in Northeast locations call 201-575-2076) or write 3M at the address below. 412769 0126 N-M0TI -M 1 t 9.5) U Ceramic Fiber Products/3M 219-1 3M Center St Paul. Minnesota 55101 UlHOlNUSA 3M BERTRAM D. DINMAN, M.D. -1930 May 29 TO MEMO FOR FILE ZJ- Re:' bAWSONITE Discussion with John Konzen an May 28, 1980. John Konzen indicated several new developments: 1. Dupont has reported that potassium titanate given by inhalation to experimental animals has produced lung cancer and mesothelioma. However, it is very important to note that doses were the order of 40 ,000 fibers per cubic mater. 2. They have received an advance notice for rulemaking by EPA which states that "if fibers are longer than 10 micra and less than 1.5 micra in diameter, such are not to be considered as a substitute for asbestos". Clearly they are basing this position on the work of Merl Stanton; the fibers industry will be vigorously fighting this proposal. 3. An in-house epidemiologic study (Enterline?) which reviews mortality experience of 3,000 workers with 30 or more years interval since first exposure and 20 or more years work exposure! There is no excess of any tumors of any type except possibly for a small excess of rectal CA. It should be noted that these were workers exposed to glass fiber in the course of manufacture; the special facts of life as regards this exposure must be clearly understood (see below). 4. He also reviewed for-me the fact that endotracheal insufflation of fibers of the critical size (as specified by Merl Stanton) has been carried out in experimental animals by Kuschner, by Gross, and by Gardner over the years, and in no cases have they succeeded in producing lung tumors. 5. Konzen feels that the Zeolite problem in Anatolia (central Turkey) is rather curious for several reasons: a. People who live in the area are cnly spottily affected. They do move about from village to village in the course of living in the area and this complicates the understanding of what the pertinent risk factor may be. b. The "mesotheliomas" which are produced there behave rather curiously, i.e., the people live 2, 3, 4 or more years with these tumors and did not die, which is quite ccntraxy to the behavior of the tumor. It is extremely important that cne understands the aerodynamic properties of fibers to understand what human work exposures mean. The ordinary artificial fiber is 5-9 micra in diameter and of variable length. 412769 0127 ALCOA 2. Apparently because the aerodynamic properties-are such configuration-- as compared with spherical particles?--repeated studies of dust concen trations in glass fiber forming and processing operations reveal that the -- .concentration range is anywhere from 1-5- fibers per cubic meter. More often than not, the number of fibers approaches 1 or maybe less than 1. Clearly, fibers of the size associated with fibrous glass do not apparently suspend very well in air. Sampling studies have been reported by Corn and Esmcn in the AIHA over the last several years and have confirmed this. It is also important to state that of the suspended fibers, 80% of the suspended fibers are 3-5 micra or less in diameter, and 20% are less than 1 micra. What we are saying, in effect, is that workers who are handling these fibers have been exposed to critical size fibers as defined by Stanton, but the absolute number of these fibers in their ambient air are extremely small, more often than not being fractions of fiber. (The bottom line of this issue is that the Stanton model, while interesting, represents the same old problem in carcinogenesis, that is, massive dosing. Stantcn, during his lifetime, was very clear to state that this model was interesting for the use of study of carcino genesis, but its relevance to the real world is cne which he would not attempt to draw. Nevertheless, it seems that our friends the regulators are not going to be bothered by fine questions such as this and are vigorously attempting to restrict the use of any type of fibers. . At the bottom of all this, I presume, is the same old question of the dose/response relationship in carcinogenesis and the role of massive dosing in production of neoplastic disease. - Ultimately this issue is going to be settled in Court since the regulators seem to be hell-bent for leather to regulate man-made fibers out of business. If Alcoa wishes to reactivate the Dawsonite situation, I think that our people should be acutely aware of the problem since they are talking about fine fiber generation. If we are deadly serious, I suspect we are going to have to pay our dues with TIMA; they are the people who are generating all this information. I don't know how much longer we can, in good conscience, sponge off Owens Coming and/or Elkem and Guthe. It would be advantageous to review our insufflation experiments (Gross, see file) once more; these did indicate acute changes but which did not associate with tumors in any regard. BERTRAM D. DINMAN, M.D. BDD/db copies to: T.B.Bcnney Robert Janes Earl Rumberger My file on Dawsonite is available for your perusal. 412769 0128 n It is extremely- -inportant that cne understands the aerodynamic propertiesQfLfibe-PS- to-understand- what human exposures fyas mean* The ordinary fiber-is 5-9 ijiicra in diameter and of variable length. Apparently because the aerodynamic 'properties is such configuration--as compared with sphheerriiccaal-l-pparticles?--repeated studies of dust concentrations in glass ---------------- : ^ 'operations reveal that tie range is anywhere from 1-5 fibers per cubic y- : "V mater. More-often-than- not, the- number- of fibers-approaches 1 or maybe. Clearly^, fibers-of the size associated- with fibrous glass do-not apparently~suspend wery well m air. Ihe ^ u Com and Esmcn in the AIHA'over the last several years. A reported by- - C- 0- - .- It--iis- a-lso-important-- to- state that of the suspended fibers, 80%-of"the_ ,\ suspended fibers are 3-5 miqra or less in diameter," and1 20% are less-than- \ lunierev Whad-we-arer sayingt- in effect , is-that-workers whu arediaiun mu these-fibers have been exposed-- -te-critical 'size-fibers as 'defined by-- Stanton, but the absolute- number of these fibers in^ air are- extremely- small, more, often-than notbeing fractions of fiber. fThe-betfeom-line- of this issue is that the"Stanxcn model. the same old-probl i, that is7 massive-dosing. Stanton^. during-his--was- very-Clear- Lu sLdD5~LlldL this model-was interesting-fer--the-use-of- stuejy of carcinogenesis, -but its- relevance-- to the- real- world -is- one- which-he would-Trot-attempt-tcx~draw . 'Nevertheless-, it - seems-that-"Our--frierids~the Regulators are not going...to be., bothered- by-- fine quest.inns-sueh-as^rhis- and-are vigorousiy-attempt-ing-- to - confine the-- use~- any-type-of- f-ibers. Af-tho--bottom-of- aH-this-pT presumst is-the-.. same old question 'of - the- dose/respons^^uesiiae--relationship, in .carein-___ [ "7 genesis and-the-rola.of- massive"dosing in-produetierr-of disease^ Ulflmatoly-th-is--issue-is going to be settled in Court since- the-regu-latocs -2- 412769 0129 1980 May 29 MEMO FOR RECORD -tr- Re: DAWSONTTE Discussion with John Konzen on May 28, 1980. \ John Konzen indicated several new developments: \ 1* Dupont has-reported that potassium titanate*by inhalation has-produced /JITT ~--:--------------- -------------- --* ^^-experimental,.animals)lung cancer and mesothelioma. However, it is very important to note that doses were the order of -40-^090--fibers_per cubic neterV 2. They have received an advance notice for rulemaking by EPA which states,, that "if fibersXlonger than 10 micrA- and less than 1.5 micrctin . diameter, nte-ie-not to be considered.as a substitute for-asbestos". Clearly-they are lasing this position on the work of- Merl- Stanton'and-- the industry-will be\ vigorously fighting this proposal. 3. An-in-house-epidemiologic-stucty (Enterline?) which reviews mortality experience of 3 r0.00_ workers with 30 or more years interval since-first- - exposure and 20 or more, years, work exposure! There-is no excess- of any-tumors -of-any-type except possibly for a small excess of rectal CA. it-should--be noted that theset were workers exposed to glass fiber in the~couree-of~TTKmtufacrt^^ \he_ special-facts of life as regards this..exposure- must be clearly understood (see below). 4. He also-reviewed for me the fact that^insufflation of fibers-of^ the critical size/ as afiffnarSled.by- Merl- Stanton'') have been carried out (-*1 in experimental animals by Kuschner, Gross, and Gardner-over the years-, and -in-no- cases-have--they--succeeded urprodue-ing"lung--tumors. 5, ^ -i- 412769 0130 coom t<~> han^hpnt fn-n i jto-regulate- fibers outr of-business^. / If-Alcoa wishes- to-reactivate- the Dawsonite situation, I think that our--, people--should-be-acutely aHare-of--thfs^ sirtee--they-are- talking about these fine fiberepgoncration. If we are deadly, serious.,. 1 suspect we are-going to have-to- pay our dues- with *l^|A; -they ary r^_-pprvpia-iA^a-no generating-- alb--this'information. I don'-trknow-how-much-longercan, in-good conscience, sponge-off .Gwens"Coming-and/yor Elkem and-Guthe-. It would bs-advantageous-to -review our insufflation experimeeants onco- more; wlixijlr*. /J - changes but-whieh- did- not' associate with tumors -in-any__ regard) -- --KcnzeK feels that the Zeolite problem in Anatolia (simple Turkey)- -P is rather curious forseveral reasons: A.-- Peop-jte'vho'live .in the-area-are- oily spottily. affected. \/ They- dV move-about from village to village in the-course, of living^ ill the area and this complicates the understanding-- of what- thei? risk'JL&r- l^cJPrx; J f^ve. B.-- The- "mesotheliomas " which are. produced^behave-rather - curiously^-- i-.-er-, the-peeple. live. 23, 4 or more years with these tumors and-did- not die, fyhich is quite contrary to the behavior,of. -the--temor.- 412769 0131 FROM HAIG G. SAKOIAN PITTSBURGH OFFICE B. D. Dinman Pittsburgh 7AB 1979 July 30 RE: ASBESTOS SUBSTITUTION Attached is a summation of asbestos materials currently in use at Alcoa locations. Included in the listing are: The material and its use - The number of plants using the material Whether or not there is a potential for employee exposure Potential replacements, if available -- and manufacturers (Page 10) Much effort has been extended to reduce and eliminate asbestos uses in most locations. However, as can be seen by this report, many uses still exist. Because the continued use of asbestos products may result in unnecessary health hazards and concerns to our employees, as well as additional costs to Alcoa to comply with specific provisions of the OSHA Standard, we believe it is in Alcoa's best interest to continue eliminating the use of asbestos products wherever possible. This does not mean that all existing asbestos should be removed immediately which, as in the case of sprayed-on insulation, could create unnecessary exposure potentials. Rather, a systematic effort should be made to discontinue uses, when feasible and practical, by substitution or elimination. By creating this listing and maintaining frequent updating via feedback from all locations, each plant can be provided with the information necessary to attain this goal. Mr. J. M. McCollum, Pittsburgh Office Mechanical Engineering, has been coordinating such an effort for asbestos replacements in potrooms. A List illustrating Alcoa's experience with potroom replacements is shown on Pages 7, 8, and 9. It is hoped that this type of registry will be extended to cover all asbestos uses for all locations. To achieve this, it is asked that each location copy this office on all efforts made towards asbestos replacement... whether positive or nega.^ve. This information will then be disseminated to all locations on a periodic basis so that each plant can profit from the experience of the others in the Company. Any questions, comments, or additions to the attached would be appreciated. HAIG G. 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Page 6 KEY TO ALCOA LOCATIONS 1 -- ATC 2 - ARKANSAS 3 - BADIN 4 - CHILLICOTHE (Wear-Ever Aluminum) 5 - CLEVELAND 6 - CORONA 7 - DAVENPORT 8 - FT. MEADE 9 - LAFAYETTE 10 - LANCASTER 11 - LEBANON 12 -- MARSHALL (ACPC) 13 - MASSENA 14 - MOBILE 15 - NORTHWEST ALLOYS (ADDY) 16 - PT. COMFORT 17 - REA MAGNET WIRE 18 - RICHMOND, INDIANA 19 - ROCKDALE 20 - TENNESSEE 21 - TIFTON 22 - VANCOUVER 23 - VERNON 24 _ WARRICK 412769 0139 C <11 *o .<D O' Id e e& a P tU i--i x -P P S <d +J ' to o >i o (0 -P tr At 1) CO 0X3 V id -r-i XI CO tl ea O X <<Du 3 teo CO X XX a) x *0 -p to > C 3 a> o ai X PE a: a tu -P 4J tu tu XI X oo xx id <a -P -H PP <d tu X -P <0 (0 tu tu >> p -p tu (U to p to > o o X o a. in ri A P o a a <u <d XX to to i--c Ho tu CO s r-1 <o to At P O U T3 rO rH T5 <I) c -P <d x x P to P *H rH 4-> 0> ' -p -p to P to 43 CO X (0 C H to x a> 3 B ~ 0 3 PX ** in in o C -p (1) IN <N x 3 CM CM p x - X II H H4J CO P 44 CO ai 44 to G 44 44 4J to 03 tu ai 0) W >i to O XX 0) 0) P (U X O X P-P+l O O' tU X a s c x x tu a_) a> a) tu to tn 44 xi xx p xi to XU o -P to p to O' P <D 3 3 ,E-< M O oo cd ai os os CO 3 p -H -P <u O O O O id E-i Eh Eh Q to to p tu o x g to H 4J tu CO *r--j CJ os CJ PS A H u CJ} a 4J CO Ip p >1 p p ubb u1 1 cO E E G <u tu a CJ CJ C CJ O H *H UH 4-1 H <0 OO <D -H Qj rH CO Ch a < rH rH <1) JG CO 4-J 0c 04 0 H 0 4-J 4-J <0 rH <D a r-H w G cO H U u id id 3C tu tu to to to to id id X X ra r- a) x X CO ss cn JT* 11 1 u a o1 0) iH 4J pH H bc 1 *p Ep CD id u 4-J }H 0 Cn CD U 3c 0 O H P 4J U cO 4-J p-H CO P IH CO (D c aM D CO id id c cc CD tu tu CO CO CO CO CO to <a id id S - At O G -P P P a p id id CQ S tu tu sz o 44 id c lt>u x <D > *H -pH 0 0 O 4J a Ua *H X X CO B o< VH CO cO cO CD CO 43 rH h a) <0 cr CO 04 +J M &4 <0 cO -H a) o C -P ro CD CD fO r| *H eU rH cO 0 SC >. BB CO cO CO CO < 2 a. --' c 0 *H 4-> CO r-i P CO c H u CD > 0 u 4-J 0 04 CO CO 10 rH O' 0 u a) 43 CN z-: in r-' 1 Pa VO X ro <D l 4-J O (0 =*= 3 cO Gc 0) CD CO CO CO CO CO cO s2 a; ac oo H 'H PP PP <0 (0 O' c tu p X ,ra g X X 1 S O id G G CD s CJ} Pi b 04 X 3 o cj HG Xc id p 0H CJJ 4-J >1 r<H0 id P s (0 rXH MG cO 412769 0140 ASBESTOS -- POTROOM USES 0) >4gop-1 <<M1G) 13 pH (0 i--i 3co 10 0) CO u c <pu 4CJO 0) i--1 MM-H4 0) E -pH 03 -- P +J 3 CO P C cu XI XI XI (0 3 H i a **-< o oE \ 4J cu T3 Po P P T3 CU O <0 (U O -O VO 3 JZ O P C -P tr> O 0) (0 O -P O c' a(0 W2oD 3 >, c (0 P 3*3 C o H c wC3 C CO O S3 p p<0 pH (30 H 3 <0 (O0 <d C -P s m 03 < Ph o 3 i--i Ci 3b PO -H P 1 33 3 P 03 CU 33O XI a P XI CU 3 3 ip P= P 3 3 T i CO 3 TJ \ O 3 3 n i C P a3 c i rH P .Q 3 -P O 3 C0 XI fa O 3 3 J3 P O P 3 = p Jf* H U3 3 03 1 1"1 O P *P 11 ab ii c3u 3O CU P o P pH 3 pH 3 3 CO 3P 33 P XI 3 -P XJ b P b= JC :1 pH rp c o P -P 3 o a a. < 1 412769 0142 PRODUCT__________ ,,Pyro^texT*i Fiberseal Products Refrasil NorFab Yarns; Fabrics Fiberfrax Hi-Temp 270 Ceramic Fiber Products ASBESTOS REPLACEMENT MANUFACTURERS SUPPLIER Newtex Industries, Railroad Ave. P.O. Box 25 Victor, NY 14564 Inc. Pyrotek Incorporated East 9601 Montgomery Ave. Spokane, WA 99206 - or Box 77 - R.D. #1 Claremont Rd. Carlisle, PA 17013 - or Santa Fe Springs, CA HITCO Division of Armco Steel Middletown, OH 45042 Amatex 1032 Stanbridge St. Norristown, PA 19404 The Carborundum Company Insulation Division P.O. Box 808 Niagara Falls, NY 14302 Penn Compression Moulding, Inc. Burton Street Pittsburgh, PA 15218 Kaowool Babcock & Wilcox Cem-Fil Corporation Two International Plaza Drive Nashville, TN 37217 Keller Glove Mfg. Co. Plumsteadville, PA 18949 Page 10 TELEPHONE 716/924-9135 509/926-6211 717/249-2075 215/277-6100 716/278-6221 412/351-4004 615/361-4664 215/766-8818 HAIG G. SAKOIAN 1979 July 20/eds 412769 0143