Document rX36XOLvJn6Vxr69KX4pG1Ne

FILE NAME: ALCOA (ALC) DATE: 1983 July 14 DOC#: ALC022 DOCUMENT DESCRIPTION: Unpublished Company Report with Comments At > *\ t * 1 from E- B r o o k s p a r k e r ROCKDALE WORKS -4 SUPERINTENDENTS ROCKDALE WORKS 1983 July 14 RE: INDUSTRIAL HYGIENE TECHNICAL BULLETIN - ASBESTOS EXPOSURES We recently received the attached Industrial Hygiene Bulletin dealing with asbestos exposure. Rockdale's practices for handling asbestos conform to the policies set forth. However, there is one area where additional sampling will be required. That area is in the automotive repair shop when employees are working with brake linings. As soon as it can be scheduled, we will be conducting tests to determine employee exposures when this work is being done. If you know of other areas where work is needed, please let me know. E`. BROOKS PARKER EBP/mz Attachment cc: (without attachment) A. G. Clayton J. E. Richter ARD 040588 *C . Industrial Hygiene Technical Bulletin No. 83-3 Date: 1983 Juna 15 RE: ASBESTOS EXPOSURES* Due to the very serious nature o f asbestos exposure hazards, a closer look was.taken at our policies and procedures for .controlling such ex posures. Starting 1n 1978, Alcoa Implemented an Asbestos Replacement Program with th objective o f making our operations as free of asbestoscontaining materials as possible. While the program has met with con siderable success; there are s t i l l some applications where acceptable su bstitutes have not been found. Likewise, we currently have numerous applications where asbestos products were used 1n.past construction and are s t i l l 1n place. This situation may pose a-potential health hazard In the event that asbestos-containing materials become capable.of fib er release (1 .e . due to deterioration, water damage, e t c .} , or during ren ovation or demolition a c tiv itie s . The purpose o f th is technical bulletin Is to c la r ify Alcoa's policy and procedures for job tasks Involving exposures to asbestos fibers. I t ap p lie s to both renovation or demolition o f asbestos-containing m aterials, as well as routine or rep etitive job tasks Involving asbestos exposures. Attached please find a one page flow chart en title d "Asbestos Exposure Procedures" which summarizes the requirements outlined in the following te x t based upon job a c tiv ity and a ir monitoring data. I . DEFINITIONS A. "Asbestos fiber" means a fibrous form o f asbestos longer than 5 microns with a length-to-diameter ratio o f at least 5'to 1, and with a maximum diameter o f 3 microns. B. "Friable asbestos" means any material that contains more than 12 asbestos by weight and that can be crumbled, pulverized, or * reduced to powder by hand pressure when dry. C. "Action Level" is defined as 0.1 fibers/cc (8 hour TWA). Med ical surveillance, a ir monitoring and employee training require ments are triggered at the action le v e l. D. "Alcoa Permissible Limit (APL)" is defined as 0.5 fibers/cc (8 hour TWA). Respiratory protection is required when exposures may exceed the APL. Likewise, a respiratory protection program (employee train in g, f i t te s tin g , medical approval, e tc.) must be implemented. . "Routine or Repetitive Job Tasks" means employees engaged in work a c tiv itie s involving exposures to asbestos fibers on an average frequency o f an 8 hour s h ift per month or greater. (Ex amples include working with marinite headers, trough lin in g s, thermocouple wire, brake lin in g , e t c .) . Al A ARD 040590 Industrial Hygiene Technical B ulletin 1983 June 15Page 2 F. "Renovation or Demolition" means those a c tiv itie s involving the removing, stripping, wrecking, or taking out o f friable asbestos from any structural member. (Examples include removing asbestos pipe insulation, furnace tearouts, e t c .) . I I . JOB CLASSIFICATIONS A. Routine or Repetitive Job Tasks. The Industrial hygienist should assess a ll Job tasks involving routine or rep etitive exposures to asbestos fib e r s .' (Examples given in Definitions se ctio n .) Industrial hygiene sampling for asbestos should be performed i f such is not already the case. I f asbestos concentrations are below the action le v e l, and you are not relying on engineering controls ( i .e . local exhaust) to reduce the airborne concentration, no further action is required, .pending process or product changes that might potentially In crease the airborne fib er concentrations. Areas relying on en gineering controls to reduce airborne asbestos fibers should be sampled a t lea st annually to evaluate the effectiveness o f the controls. I f exposure levels are between the action level and APL, employees must be trained in the safe handling o f asbestos and receive medical surveillance. Routine monitoring should be performed on a 6 month b a sis. When exposures are found to equal or exceed the APL, the procedures mentioned above as well as respiratory protection w ill be required. Disposable protective clothing may also be necessary. . B. Renovation or Demolition Job Tasks. * Typically, maintenance tasks involving renovation or demolition a c tiv itie s represent lik e ly potential excessive exposures. The prudent course for such job tasks would be to automati c a lly im plement the appropriate precautionary measures: (1) medical sur v e illa n ce, (2) respiratory protection, (3) employee training and (4) protective clothing (as necessary). Wherever possible, wet down the material to be removed to minimize dust. Do not use water i f ele ctrica l or other hazards ex ist ( i . e . , water on phos phorous-containing refractories may result in phosphine gas formation). The following sections o ffe r supporting detail concerning re quired industrial hygiene safeguards when working with asbestoscontaining m aterials. I I I . REQUIREMENTS A. Medical Surveillan ce. Employees exposed above the action level on an average fre quency o f one eight hour s h ift per month or greater w ill re ARD 040591 1 Industrial Hygiene Technical Bulletin 1983 June 15 Page 3 ceive an annual medical examination. This periodic evaluation w ill include a questionnaire to e l i c i t the symptomatology o f respiratory disease, pulmonary function tests (FVC and FEVi.o), and a chest roentgenogram. Employees should be n otified o f any abnormalities within 30 days o f such a finding by the evaluating physician. . . . B; Employee Training A ll employees exposed to asbestos concentrations above the action level shall receive annual training in the proper handling o f asbestos. This program should include an ex planation o f the following: (1) The requirements outlined in th is .b u lle tin . (2) Hazardous properties o f asbestos. (3) Work practices and engineering controls utilized to reduce exposures.......... _ ............ (4) Safe work procedures for handling asbestos-containing m aterials. (5) The effectiveness o f personal protective equipment. Attendance a t such training sessions should be documented and file d app_ropriate!.y:. ................................... . . . ................ - ... C. A ir Monitoring A ll tasks involving potential exposures to asbestos require baseline sampling. Routine a ir monitoring should be contin ued on a six month basis for routine or. repetitive job tasks with asbestos concentrations at or above' the action le v e l. I f exposure levels are found to be below the action le v e l, air monitoring should be performed i f process or product changes occur which might potentially increase the airborne fiber concentrations. I f reliance on engineering controls is necessary to reduce .exposures below the action le v e l, annual monitoring should be performed to evaluate the effectiveness of the controls. 0. Respiratory Protection Respirators are required o f anyone performing a job task whose potential exposure to airborne asbestos fibers may exceed the APL. This would include all demolition/renovation a c t iv it ie s , and may include routine or rep etitive job tasks, depending upon industrial hygine sampling data. For exposures up to 10 fib ers/cc, the following NIOSH approved respirators are acceptable for protection against asbestos fibers: ARD 040592 Industrial Hygiene Technical Bulletin 1983 June 15 Page 4 3M 8710, 9900, 9910 or 9920 AO R1070 Willson 1410 MSA Comfo II with Type F F ilte r Exposures in excess o f 10 fibers/cc require the use o f a NIOSH approved powered a ir purifying respirator, or a type "C" sup plied air respirator.- While the Alcoa Permissible Limit determines the requirement for respiratory protection, disposable respirators should be made available to a ll employees with potential asbestos exposure who desire to wear them, regardless o f their levels o f exposure. When respiratory protection is used, a respirator program in compliance with Alcoa Engineering Standard 18.1.1 must be es tablished and implemented. Annual fit-te s tin g and train in g, medical approval, NIOSH approved respirators, and written SOP's should be included with th is program. E. Protective Clothing The area of protective clothing (disposable garments) is best l e f t up to the judgement o f the plant industrial hygienist a fte r an assessment-of the job task an d -its associated dust exposures have been made. For demolition or renovation a c tiv itie s in which there is a considerable amount o f dust generation, or when fibers may accumulate on work clothing, disposable protective clothing is warranted and required. A ll contaminated protective clo th in g , as well as respirators, should be disposed o f as asbestos-containing m aterial. F. EPA Requirements The Clean Air Act regulates removal, cleanup, and disposal of . asbestos material under certain circumstances: (1) the mate r ia l is "fria b le asbestos", and (2) asbestos is removed from renovation or demolition work, and (3) asbestos material quantity is greater than 260 lin ear feet o f pipe covering and 160 f t 2 from other sources. I f only the f i r s t two considerations e x is t , only n o tificatio n procedures are required. I f a ll three conditions e x is t , Clean Air Act Regulations Subpart B, Parts 61.22(d), ( i ) , ( j ) , (1) must be followed. Contact the Plant Environmental Control Department for assistance with the above. IV. ALCOA' S ASBESTOS REPLACEMENT PROGRAM Alcoa's Asbestos Replacement Program was in stitu ted in 1978 with the objective o f making our plants as free o f asbestos materials as possible. Suitable replacements for most, but not a l l , asbes- ARD 040593 1 Industrial Hygiene Technical Bulletin 1983 June 15 Page 5 tos products have been found. E ffo rts to find replacements for the remaining applications w ill continue. I t is imperative that accurate records be kept to identify areas where asbestos-containing materials are being used, or have been used in past construction. To minimize potential health hazards associated with renovation or demolition o f asbestos products, a ll maintenance projects should be reviewed for potential asbes tos exposures prior to startin g the jo b . I f asbestos is suspected, the material should be treated as such unless laboratory analysis confirms otherwise. Samples o f bulk material can be analyzed by Alcoa's Environmental Health Laboratory. Asbestos materials in good condition which do not represent lik e ly exposures should not be removed simply because they contain asbes tos since doing so may present a greater hazard during the actual removal. However, a routine inspection program o f the material should be implemented to insure that the situation does not change. I f you have any questions concerning the above, please do not hesitate to contact me. JOAN E . SANDER JES:sc D istribution: I . H. Distribution L ist I . H. Plant Contacts Industrial Hygienists - International I . H. Division - Pittsburgh & ATC I . H. Technicians Pittsburgh A ATC - General ARD 040594 * ---------- - ^ < AL Re l y On En g in e e r in g Co n t r o l s ? 4YES Mo n it o r On An n u a l Ba s i s 4NO No Further Ac t io n Un l e s s Pr o d u ct Or Pr o c e s s Change ASBESTOS EX POSURE PROCEDURES Job Activity Routine/Repetitive 4 -- Air Monitoring-- AU&APL Medical Surveillance 'P > APL Respiratory Protection Routine Monitoring ( 6 Mo. Basis) Protective Clothing (As Necessary) Employee Training Rnovtion/Demolition v EPA Notification Procedures (Contact Envtl, Control Engr,) Medical Surveillance (Av g , Freq8 Hr . Shift/Mo .) Employee Training Respiratory Protection Pr o t e c t iv e Cl o t h in g (As Ne c e s s a r y ) ARD 040695 AL (Action Level) * 0 .1 Fibers/cc TWA APL (Alcoa Permissible Limit) * 0 ,5 Fibers/cc TWA D i s p o s a l Re q u ir e m e n t s (Contact En v t l . Control En g r .)