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CLOSING CONFERENCE -- OSHA INSPECTION FOR 8/12/83
The closing conference with Rex McKinney, OSHA, was set for 1400 on 8/12/83. Mr. McKinney arrived at the plant at 1230 and was brought in from the Main Gate at 1300. Prior to the closing conference there was some discussion on steps that we have taken since the inspection of 6/28-7/1 concerning employee physi cals. We stated that we plan to initiate yearly physicals (including medical history, pulmonary function test and chest x-ray) for those individuals doing incidental work requiring them to remove asbestos insulation. Also stated that we would not force an individual to take the chest x-ray. However, if they
decided not to take the x-ray, then they would be required to sign a statement stating this.
He also requested medical information on the two workers, R.V. Nicol and G.E. Hoyland, on which personnel monitoring was done while they were performing job of stripping asbestos. Information given was as follows:
Last Physical Pulmonary Function Test Chest X-ray
Nicol
03/23/83
08/81
Given slip at last physical
Hoyland
11/17/82
11/17/82
Given slip at last physical
Closing Conference
Personnel present:
Rex McKinney, OSHA Charles Davis, Pipefitter Safety Representative Greg Daues Dan Campbell Mark Riddle Bob Hammann
Mr. McKinney started by stating that their tests showed 0.3 fibers/cc which is well below the ceiling limit and therefore indicated no overexposure. He stated there were three possible citation areas.
1. Work practices/wet methods - 1910.1C01 C.2.i
We were cited as the workers did not wet down the asbestos while they were removing it. It is our practice to wet down the asbestos. He has a copy of our procedures which state this. Abatement period - immediate. This has always been our practice.
2. Personnel monitoring - 910.1001 F.2.ii
Personnel monitoring must be done at intervals no greater than six months. From the data that we have given him, this has not been done. Additional search for data will be made to see if we have indeed complied with this.
Abatement period - immediate.
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Closing Conference -- OSHA Inspection 8/12/82 (Cont'd.)
Page 2
3. Employee physicals - 1910.1001 J.2
People working with asbestos shall have a physical examination within 30 calendar days. Some discussion followed concerning this when we once again stated our opinion that this initial examination is to establish baseline data. We are willing to accept data taken from earlier physicals as being the baseline data. He could not answer this other than to state that we would have to discuss it with his boss at an informal conference sometime after receiving any citations. His boss' name is Jack Fontaine and his phone number is 750-1727.
We should receive the formal citation within two weeks by registered mail. The fifteen working day period for formally contesting the citation will start the day after receipt of the citation.
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From: K.G. Christian, M.D. 8/24/83
cc: Greg Daues
Dora Sendejas, R.N. Dan Campbell Bob Hammann
8/24/83
SUMMATIONS FROM DR. SPRAUL'S VISIT:
TOPIC:
The 18 pipefitters are to be treated as other pipefitters in respect to their chest films. That is, they are to get their PA films only as routinely scheduled. No interim "baselines" are to be done.
TOPIC:
Among crafts other than asbestos worker's (insulators) who handle asbestos as a very limited part of their jobs, industrial hygiene will need to do a significant monitoring effort to assist in or to actually identify those in* these new groups that will need the full asbestos surveillance routine. It is probable that most will notneed this extensive surveillance.
TOPIC:
If an insulator or any member of another craft who is designated for asbestos surveillance obtains his PA chest film from outside or private source, it is encumbent upon us, actually mandatory by government regulation, to obtain copies of the film for the 30 year storage period. We expect to pay a charge. This may very well apply to situations outside the asbestos surveillance pro
gram in which it is important that a copy be in the files for re ference.
TOPIC:
The chest film as part of asbestos surveillance, as well as pul monary function, is expected as well as mandated. As it may be a matter of choice with others, it would be highly desirable that persons receiving X-ray requests for chest films initial in some form or place acknowledging their receipt of the request.
TOPIC:
There seems to be agreement that a most optimal system would be for the Beeler-Manske group process the films and for the OlsonWooley group to do the interpretation. This will cost some more than the present system, but this increase should not be a surprise to anybody. Dr. Spraul volunteered himself and DMEH to be culprits in this new arrangement.
TOPIC: It seems that there is universal agreement in the selection of the Ohio pulmonary function analyzer and the Spirotech recorder.
As the above items were covered thoroughly and at various times, it seems that if there are no corrections or other objections to the above, we could and should move along especially with the Ohio purchase, and the proper steps in the approved set-up on X-ray interpretation. So, if there some things that are not correct, these should be made known fairly promptly.
We will be depending upon Industrial Hygiene much in the area of compiling of lists of those to be followed because of asbestos ex posure.
KGC
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