Document rxav79ZzYNox9YRKepxKR4XNq

PLAINTIFF'S EXHIBIT < FD-lltO MtrOMM ' < Owl fartt DlwMon MtaHM April tU 1975 T* fi NcNiMWt K* A* Subject: Atbutoi Reformer: !ty previous coaaunicstlons of 11-20-72, 1*3-75 and 1*10*73 md Industrial ty|lm npwt by H. Lick of 3* 16-73 la the above referenced eoweunleatloue, the O.S.H.A. requlrwnt for per forming periodic medical amaalnations u dleeussed. It ie Of undorstand1q| froa a eonvereatiea with poo m January 15* 1973, that, per L. Teach, Dr. Blech rill reconaand at eoae future date lAat testa ere to be given end will also am the equipment neceaaaiy to perfora these testa. I have attached e copy of e prograe directive which appeared in the April 5, 1975 Boreao of Batieoal Affairs. Since ve sou know that at least one person has bom eeposad in excess of allowable limits, 1 an of the opinion . that ve could be cited. . 1 would like to i to determine the lev. ; that you sectset Dr. Block mea again ie an effort for Saline Plant to conply with this portion of the J) l/J J. D. Woods ee J. P. MeCsllue y Asbestos film 4 8008 0047 SCF-FORD-1032 DDAfit TWr> ov cAtm 8009 0048 CURRENT REPORT _ Medical atrveOance would be required when the uOy nolac doee exceeds 80 percent of the environmentel limit. * The OSHA document would limit the daily nolle dose to 90 dBA, but five yeapafter the effective date orihe standard, the limit would be loweted to 8$ dBA unless unequivocal evidence is developed to show that the lower level would not result in reduced hearing impairments. Other differences existed between the two documents with respect to certification of audiometric technicians, and changes in the formulae for determining the attenua tion characteristics of ear protectors. Environmental limit The existing OSHA noise standard of 90 dBA time weighted average for an eight-hour day should be retain ed, HOI mid. He described a program conducted by duPont which included hearing conservation measures and regular audiometric testing. During the entire program, testing diowed no evidence of hearing lots among employ* ees exposed to noise levels below 90 dBA, HOI said Dr. Hfldyard presented a aeries of dements that he considered Aould be included In any noise standard Environmental limits of occupations] exposure to noise should be set and wearing of ear protection mould be compulsory wherever the limit is exceeded, he said Noise levels vtftich exceed the limit should be reduced by engineering procedures where posribie. Periodic monitor ing of the workplace ought to be tequlrad along with preemployment and follow-up audiometric terttag with recordkeeping. Employees mould be educated in the proper use of personal protective equipment and in the recognition of rymptomt of overexposure to noise. Both employers and employees mould be disciplined for figure to comply with the standard Warning rips mould be required for those areas which exceed the standard Dr. Hildyard said The existing rtandard knowingly allows eight to 20 percent of the noise exposed population to suffer some hearing loss, Dr. Van Atta told the committee. While this is not a good standard, a large segment of industry cannot meet even Dili minimum, and an environmental Umli of 8S dBA atil) would permit a hearing toes to affect 4 to 5 percent of the noise exposed population, he said The committee should consider three mints in developing an environmentallimits^: ,* , 1. Comervstioft.ollmrlnt.MioM and by how much). 2. The prscticaKpoaribBiwf'o( macling the environ mental limit -i-gfc.Jfc-; *, 3. The ecooocafc fcnpect of (Nrlimit on industry. Omci Burinsis Some 20 written commenu wen received by the committee and Wold suggested that these be digested or summarized for use by the committee members. Some members objected preferring to review each comment in its entirety, and the suggestion wis dropped The committee siso requested that OSHA provide dsta concerning the number of citations issued for alleged violation of the current noise standard OSHA agreed to do this and oho will include the avenge siee of the establishments died for alleged violations and the decibel levels found 1271 tThe next meetings c the advisory committee an scheduled for May 9-10 and May 30-31. Both meeting wOl be held in Washington, D.C. The main business et the first meeting will be carried on by the subgroups. Written comments may be filed for the committee') consideration by sending 20 copies to OSHA Office of Standards, Railway Labor Building. 400 First St. N.W. Room 509, Washington, D.C. 20210 ' Program Directives OSHA DIRECTIVE SPECIFIES EMPLOYERS MUST OFFER ASBESTOS RULE EXAMINATIONS Employers who make a good faith offer to provide or make available, at cost to the employer, the medical examination for employees ss required in the asbestos standard, are in compliance with the standard according to Occupational Safety and Health Administration Pro gram Directive 200-17 issued on March 16. The directive is concerned with the medical examina tion requirements of 1910.93a and supplements the Com pliance Opera lions Manual with special emphasis on Chap ter* IV, V, VIII, and XIII, and OSHA Program Directive 72-1 and 2004. The standard requires and employer to provide ormake available at cost to the employer, medical examinations to employees engaged in occupations exposed to airborne concentrations of asbestos fibers. Employees are not required to take the exminationa. If an employee refuses to take the examination, it should be determined if the employer made a good faith offer. If the employer has demonstrated good faith, he in compliance with the regulations. An appropriate statement of refusal should be kept by (he employer as a record under 1910.93a (jX.6). A written form signed by the employee, to the effect that he will not take a physical examination, would be such an appropriate statement. Program Directive ~ OSHA DIRECTS INSPECTORS TO USE ONLY NIOSH CERTIFIED DETECTOR TUBES Compliance officers were directed to use only detector tubes which come from a batch certified by live National Institute fot Occupational Safety and Health, in Occupa tional Safety tnd Health Administration Program Direc tive 734 issued on March 12. The directive was issued to provide OSHA supervisory staff and field personnel with guidelines for the use of detector tubes in the auetunmt of hszirdous it- mospheres. Length of stain detector tubes have been issued for determination or HjS, SO*. 0,. and COj. OSHA specifi cations require that the tubes be tested at one-half, one, two, and four times the Threshold Limit Value (TLV) and show an accuracy of 35 percent in the lower ranges and 25 percent in the higher ranges with about 8$ percent probability of being within these ranges. NIOSH has a project to certify detector lubes is being C*eyrl|M C 1972 by Tba Bureau at Natiaaal Affair*. lac.