Document rBvpJ33wnMGw5LMG3O4bRQ60V

PLAINTIFF'S EXHIBIT ONION CARBIDE CORPOftATI ON INTERNAL CORRESPONDENCE r . O.. UBOUAX T17I 1I ,I TI EL XAAAOS CIITI YI , TIIEXAS (kJ/jL^U djr C^u/ul^ TO: M. E . Ou r d 1 n M. 0. Lindsey 1 . D. Pe 1 1 J . A. Robe rt s CC: R. A. Mendez J . B. Lever ton OATE : November 7, 1986 SUBJECT: ASBESTOS SJAMflABDS. The attached recommendation# represents this committee's study on OSHA's final asbestos standards, and its impact on the Maintenance Depar tmen t. Following the charter provided, we reviewed OSHA's occupational exposure standards 29 CFR. 1910.1001 and 29 CFR 1926.58. Our conclusions end recommendations yielded from this study, are divided into four (4) major categories. Maintenance Procedure D-12 Personal Protection Equipment Training Summa r y ' These categories are attached for your information and review. if you have any questions or comments concerning the attached documents, please contact anyone of us. K.^J. ru s t u s JL . E. Ba r n e s K. E. Martin R. E. Woodcock /md v RECEIVED JAN tg fag; ^'WFNANCE DFPr. UCC 006367 TRAINING REQUIREMENTS OSHA standards will require extensive revisions in our monitoring procedures, medical surveillance, and employee training programs. Monitoring changes are now being reviewed by the Industrial Hygiene Department. New equipment has been purchased and is currently In use. The medical surveillance program may be adequate. Representative from Health Services should review their require ments and adjust their procedures accordingly. AM employees entering a regulated area will require specific indep th training. Effective 1/17/87, OSHA will require that a "competent person or persons" be certified In all aspects of handling asbestos. We as a committee, feel additional certification will be necessary due to anticipated State demands. UCC 006368 PERSONAL PROTECT I ON EQUIPMENT OSHA's standard* changes will necessitate heavy demands for new asbestos abatement equipment. This committee recognises the urgency in placing orders for this equipment in an effort to meet OSHA' time schedule and 01111X0(1966 budget dollars. Please review our estimates listed below. Purchasing procedures cen begin upon menegement approve! of these recommendations. It should be noted that equipment needs may require updating as we adjust to the new standards In 10676. ITEM Portab 1 a'Change Facility Negative Air Pressure System HYDA Vacuums Systems Powered Air Purifying Reap. Mlsc. 1tem/Rop1ecement Parts Filters/Werning Signs Total Equipment Expenses NO. REQUIRED 3 1 6 12 EST.COST 145.000 3.000 7.000 6,000 4.000 tec.ooo 1086 TRAINING Certified "Competent Person" 2 S 2.000 Insulator Procedure Training (1066 Maintenance Training Procedure) 1087 Recommended Training Additional "Competent" People Insulator State Certification (First Quarter) t 2.000 t 7S0 UCC 006369 MAINTENANCE PROCEDURE D-12 REVISIONS Significant revisions to our Maintenance Procedure D-12 (Asbestos handling), are a direct result of OSHA's final asbestos standards changes. The reduction in OSHA's exposure limits allowed handling procedure changes from 2.0 to 0.2 fibers per cubic centimeter of air, as measured in an 8-hour time-weighted average. Consequently there is a significant impact on both personal protection requirements as well as confinement of contaminates procedures. The proposed updated Maintenance Procedure D-12 is attached in the first category. However, it should be noted that this procedure is subject to future revisions as additional OSHA standards information becomes available. UCC 006370 DRAFT STANDARD MAINTENANCE PROCEDURE NO.: PAGE: EFFECTIVE: REVIEWED/REVISED: 0-12 1 of 5 05/04/85 10/14/86 UNION CARBIDE CORPORATION Solvents and Coatings Materials 01vision Texas City. Texas SUBJECT: REMOVAL AND HANDLING OF ASBESTOS CONTAINING MATERIAL 1.0 PURPOSE 1.1 To protect the health and safety of employees directly Involved and others who may be exposed to dust/fibers In the Immediate area of asbestos-containing material removal or demolition. 1.2 To provide a standard method of safe removal and handling of asbestos-containing material In compliance with Plant Procedure I-B-8 and OSHA Standards. 1.3 To provide a standard method of disposal of asbestos-containing material from the plant. In accordance with E.P. Department guidelines. 2.0 SAFETY 2.1 Breathing asbestos dust may cause cancer and lung disease. 3.0 EXPOSURE LIMITS 3.1 Employee 8-hour time-weighted average (TWA 8) exposure to airborne concentrations of asbestos fibers shall not exceed (0.2) fibers, per cubic centimeter of air. 4.0 PROCEDURE 4.1 A Hazardous Work Permit will be secured for any work with asbestos. 4.2 Where feasible, a negative pressure enclosure will be established before asbestos removal begins. 4.3 Caution signs will be posted at all approaches to areas where removal, demolition or handling of asbestos-containing material Is being performed. UCC 006371 STANOARD MAINTENANCE PROCEDURE NO.: PAGE: EFFECTIVE: REVIEWED/REVISED: D-12 2 of 5 05/04/85 10/14/86 UNION CARBIDE CORPORATION Solvents and Coatings Materials Division Texas City. Texas SUBJECT: REMOVAL AND HANDLING OF ASBESTOS CONTAINING MATERIAL 4.3.1 The signs will conform to 20" x 14" vertical format. R 4.3.2 The signs will state: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA 4.4 An appropriate barricade, using green tape, will be erected around the perimeter of regulated areas as a supplementary, protective measure to discourage unauthorized entry. 4.5 Insofar as practicable, demolition, removal or handling of asbestos-containing material will be performed while the material Is In a sufficiently wet state to prevent emission of airborne fibers exceeding the exposure limits. 4.6 Removed Insulation will be wetted and placed directly into labeled plastic bags or other suitable containers. 4.7 In cases where this is not practicable, place plastic sheeting beneath the job site, mist spray the removed Insulation with water, then place In plastic bags. 4.8 Vacuuming will serve as an effective alternate cleanup method. 4.9 Where a portable change facility Is provided, entry to and from the regulated area must be through the change facility. UCC 006372 STANDARD MAINTENANCE PROCEDURE NO.: PAGE: ________ EFFECTIVE: REVIEWED/REVISED: D-12 3 of 5 05/04/85 10/14/86 UNION CARBIDE CORPORATION Solvents and Coatings Materials Division Texas City. Texas SUBJECT: REMOVAL AND HANDLING OF ASBESTOS CONTAINING MATERIAL R 4.10 Containers used for disposing of removed asbestos material will bear a caution label readily visible and legible which states: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD 4.11 All external surfaces will be maintained free of accumulation of asbestos fibers. Scaffolds used for this work, will be cleaned. 4.12 Asbestos waste, scrap, debris, bags, containers, equipment and contaminated disposable clothing for disposal will be collected and sealed In impermeable bags or other closed Impermeable containers and placed in place in an area to where damage to the containers would be at minimal. 4.13 All pipe or equipment insulated with asbestos containing will be stripped before taking to Salvage or Investment Recovery. 5.0 PERSONAL PROTECTIVE EQUIPMENT R 5.1 Respiratory Protection - Employees engaged in the spraying (wetting-down) of asbestos, the removal; In the demolition of pipes, structures, or equipment covered or Insulated with asbestos; and in the removal or demolition of asbestos insulation or coverings shall be provided with respiratory equipment as follows: UCC 006373 STANDARD MAINTENANCE PROCEDURE NO.: PAGE: ________ EFFECTIVE: REVIEWED/REVISED: D-12 4 of 5 05/04/85 10/14/86 UNION CARBIDE CORPORATION Solvents and Coatings Materials Olvlslon Texas City. Texas SUBJECT: REMOVAL AND HANDLING OF ASBESTOS CONTAINING MATERIAL 5.1.1 An air purifying respirator may be used to reduce exposure below permissible limits, when the celling, or the 8-hour time-weighted average (TNA 8), airborne concentrations of asbestos fibers are reasonably expected to exceed no more than ten times the PEL limits. This consists of a half face dual cart. Respirator with type "H" filter. 5.1.2 An air powered purifying respirator will be available at employee's request. 5.1.3 A pressure-demand, supplled-air respirator shall be used to reduce exposure below permissible limits when the ceiling or the 8-hour time-weighted average airborne concentrations are reasonably expected to exceed 10 times those limits. 5.2 Special Clothing - The supervisor shall provide and require use of special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed. Contaminated clothing should not be stored in lockers. A dally change Is mandatory, more frequently, if conditions warrant. A 5.3 Hygiene Facilities and Practlces- 5.3.1 5.3.2 5.3.3 A portable clean change facility will be provided as necessary, adjacent to and connected to the regulated areas. For the purpose of small, short term operations, an HEPA vacuum or glove bag may be used. A permanent change area is provided for employees use as a follow-up for small short term operations as necessary. UCC 006374 STANDARD MAINTENANCE PROCEDURE NO.: PAGE: EFFECTIVE: REVIEWED/REVISED: D-l 2 5 of 5 05/04/85 10/14/86 UNION CARBIDE CORPORATION Solvents and Coatings Materials Division Texas Cltv. Texas SUBJECT: REMOVAL AND HANDLING OF ASBESTOS CONTAINING MATERIAL R 6.0 TRAINING 6.1 All employees entering a regulated area will be trained prior to and annually thereafter on: 6.1.1 Methods of recognizing asbestos. 6.1.2 The health effects associated with asbestos exposure. 6.1.3 The relationship between smoking and asbestos In producing lung cancer. 6.1.4 Operations that could result In exposure In asbestos, the importance of necessary protective controls to minimize exposure including, as applicable, engineering controls, work practices, respirators, housekeeping procedures, hygiene facilities, protective clothing, decontamination procedures, emergency procedures, and waste disposal procedures, and any necessary Instruction in the use of these controls and procedures: 6.1.5 The purpose, proper use, fitting Instructions, and limitations of respirators. 6.1.6 The appropriate work practices for performing the asbestos job. 6.1.7 Medical surveillance program requirements. 6.1.8 A review of this standard, including appendices. 6.2 All other Maintenance employees will be trained every three years. 6.3 Training records will be maintained by the Maintenance Department with a copy to the Safety Department. ID#0084y/1vh UCC 006375