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|| PLAINTIFFS || EXHIBIT If WH-888 Fm. Personnel Relations win 222-7263 oats March 10, 1976 Suoiep Industrial Hygiene Asbestos Seminar P. L. Combs L. P. Connors D. E. Lindahl S. F. Guthman cc: R. B. Hart N. N. Goldberg The proposed asbestos standards when enacted in July, 1976 will have a significant effect on American industry* A few primary suppliers will go out of business; secondary users of intermediate asbestos products will be trying to find substitutes and the price of asbestos will continue to rise* There is a distinct possibility within the next ten years, asbestos products no longer be available or legal to use. An asbestos substitution program has been initiated within and without Westinghouse and there are materials available which areas good as,.if not better than, asbestos. Substitutions for general maintenance items such as pipe lagging, gloves, insulating materials, welding curtains, etc. are already available and in use at a number of Westinghouse locations. Finding substitutes for asbestos based papers, Micarta, cloth, resins and ceramics could open up new product lines within these application areas. Part of the selling pitch would be obvious - no exposure problems. The continued use of asbestos products will be prohibitively costly and impractical for the following reasons: 1. Sources of supply will become unrealiable since the new standards are not attainable even when using the best available technology. 2. Few, if any, intermediate or secondary users of asbestos are going to invest the capital necessary to install the best available technology when doing so will still not bring them into compliance. Drr\r1 OfOO 06000122 Industrial Hygiene Asbestos Seminar Page 2 3* Use of asbestos in any form requires identificationt samplingf medical surveillance and extensive record keeping* Over exposure and this will be the rule not the exception, will require establishment of "Regulated Work Areas" - hazard signs must be posted, entrance and exit to these areas restricted, a daily log of employes maintained, extensive sampling and medical surveillance on a continual basis, employe training programs, . incorporation of the best available technology, separate wash rooms, lockers and shower facilities, daily uniform changes and approved respirators, maintenance of medical and personnel records for forty years and finally, a formal written compliance program which must be submitted to CSHA upon request. 4. The Ihvironmental Protection Agency (EPA) is also reformulating its regulations with respect to exhausting asbestos dust to the atmosphere. This new standard also covers disposal of asbestos waste. Both of these items are extensive compliance areas in and of themselves. 5. Increasing employe allegations (Workmen's Compensation claims) of lung diseases which have been caused or aggravated by asbestos dust exposure. In view of the circumstances, this department strongly reconmends that you institute an asbestos substitution program versus trying to come into compliance. It trill be much cheaper in both the short and long terms. To facilitate substitution, asbestos usage can be broken down into two primary categories which are: building and maintenance materials used in facilities construction or repair and second, asbestos materials used in the manufacturing process. 1. Effective insnedLately, all asbestos products used in the maintenance function should be identified, isolated, replaced with a substitute and then legally disposed of. A specific individual should be given this responsibility and a time schedule to accomplish this task. Typical examples of asbestos usage within the work engineering and maintenance fmictions are: asbestos gloves, welding curtains, heat shielding composite such as transite, pipe lagging or filler material, washers and packing material, electrical wire and on new or remodeled facilities, asbestos ceiling tiles or room dividers. 2. The second and probably more difficult task is product substitution on intermediate asbestos based products sold to our customers. Members of your Marketing and Engineering staffs should be assigned the same task of identification, customer contacts and reengineering and design of substitute products. Industries that develop substitutes first will have a competitive edge on the market since all users of asbestos products will come under the act. ' Produced 3/93 i 06000123 Industrial Hygiene Asbestos Seminar Page 3 // // Arrangements are being made to air sample your asbestos usage but this will take time and the purchasing of testing equipment. Without testing we can confidently forecast overexposure or non-compliance in the following areas by plants* All Plants - In the works engineering and maintenance functions where asbestos products are used. No plant is properly disposing of asbestos waste products or ventilating asbestos dust. If any plant has asbestos ceiling or wall tiles or dividers , these areas must be sampled also. Bedford - The use of asbestos weave or cloth from unpacking through the Slitting and packaging group. Additional problem is general plant contamination by asbestos (hist. Asbestos paper -- unknown but probable overexposure. Manor - Use of product RG144 asbestos powder. Receiving-Storage snd final use plus general plant contamination. West Mifflin -- Manufacture of laminated Micarta using Bedford's 5J&6 asbestos paper. From unpackaging to sawing the final laminate. Use of paper is questionable, sawing of the laminate is definite. Plant contamination with saw dust. Derry - Assembly areas where asbestos rope, tape and weave are used. Areas using transite,spacers or transite plates for placement. Very probable asbestos talc problem which is presently being researched. The Grinding Department when any of the above containing assemblies have to be cut, scored or finished. Attached is a copy of the proposed asbestos standard, all pass outs given at the seminar, the most important of which is asbestos substitution lists, and other miscellaneous information. If asbestos substitution can not be made, establishment of a facilities planning group must be made to isolate a manufacturing area within each plant, design and install (best technology available) equipment and revise your current facilities budget. As further communications on this subject are received they will be forwarded to you as soon as possible. G. H. Schilling, Supv. Personnel Relations 06000124 Produced 3/93