Document v64EQXQNJE72p16M65ZM5L4Nb

E3 S O K! (S3 Di5V" IP^ES 0 E= 5 G3 INTERDEPARTMENTAL COMMUNICATION TO: Kr. E. B. Hollingsworth FROM: J. D. Rauch SUBJECT: OSHA INSPECTION - Akron,N,Y. Plant cct Mr. G. E. Wilson - Portland Mr. K. L. Gipson - Portland Mr. H. W. Peele - Wilmington Mr. C. W. Lchncrt > Tigard R&D date* February 9, 1973 location: Wilmington LOCATION: Akron At about 9:00 A.M. on Feb. 7. 1973, Kr. Harold Pauly and Mr. Robert Boyd arrivod at our office and presented their credentials as Inspectors from the U.S. Department of Labor Division of OSlIA. They had a file from the Bureau of Mines that Indicated we had an asbestos employee exposure problem in our Joint System operation. The Bureau of Mines had refered this problem to the Department of Labor because a recent ruling does not allow the Bureau of Mines to make inspection beyond our calcining process. Mr. Boyd made an OSHA Administrative check. Ho noted that we had all of the required OSHA posters la proper position, recorded data regarding number of employees, our OSHA accident og, first aid equipment, etc. Mr. Boyd left the plant shortly after 2:00 P.M. and did not return. He was assisted In his collection of information by E. G. Foley and R. G. Schiffcrle. Mr. Pauly was conducted to the Joint System Department by W, J. Hammer and was lator joined by Mr. Schifferle. Several air monitoring devices were either attached to workers in the area or located in general work areas to establish an eight hour exposure time. Mr. Pauly concluded hla testing at about 7:30 P.M. and departed from the plant at about 8:00 P.M. ' I had an opportunity to discuss the whole: testing program with Mr. Pauly before he left the plant. He wanted to make one point clear, that his function was not to harass, write citations, or Impose fines. He had been advised that we had an asbestos problem and was running air sample tests only. He did take.the time to point out potential problem arcao where we can expect problems with OSHA at a later date If his ar sample tests indicate excessive concentrations of asbestos particles greater than 5 microus In length. These areas of potential problems were discussed in;detail using his copy of the Federal Register, Vol. 37, No. 110 dated June 7, 1972. The major portion of our discussion centered around the items listed on page 11321. 1. "Establishment of a respiratdr program, (a) The employer shall establish a respirator program in accordance with the requirements of the American National Standards .... " It was conceded that we had established a proper respirator program in the Department. Iloweve it was pointed out that the workers on the first shift were not wearing approved respirators even though they had been supplied and were readily available. The second shift wao noted to bo wearing properly approved respirators when they reported for work. Mr. Pauly Interviewed evcral of the employees on both shifts and found that the first shift did not wear tho pproved respirators for various personal reasons. He also noted that the second shift employeeo wore wearing approved respirators and was advised that thoy used them as a matter of course since the time of issue. Mr. Pauly further advised that he had a diocucslon with, the Department Union Steward, Mr. J. Dean, and advise him that according to OSHA rcgulatlona all of the Department Employees had to wear approved rcaplratlors as a condition of employment in tho Department. I will have to take this stand in the future and hope that we do not run into a test esse. SGP 0006719 - *. . . I -2- 2. Caution Labels - "(1) Labeling. Caution lcbolo shall bo affixed to all raw materials. mixtures1, scrap, waste, debris, and other products containing asbestos fibers, or to their containers This r.ron scorned to be of major concern to Hr. Pauly, Ho noted that our inbound bags of asbestos meets the required label requirements. Ho also noted that none of our finished products, bags or palls, have this asbestos caution label. We discussed this to some . length but I was unable to sway his thinking that these labels were required. Wo touched on many other items listed in the Federal Regioter that should be mentioned. Asbestos work areas should not be cleaned with a broom. This tends to stir up dust and increase the concentration of asbestos fibers in the oir. We should use a power sweeper with an approved filter system. The paper bags that our asbestos is shipped in must be disposed of by collecting then in a plastic bag that has the required caution label. The employer ohall provide special clothing such ao whole body coveralls, head coverings, gloves, and foot coverings for any employee exposed to air born concentrations of asbestos fibers which exceed the colling level prescribed. In connection with this clothing provision requirement wo must provide e separate change room for these employees, two seporate clothes lockc.ro, to iaolato contaminated clothing from the employees street clothing. Further we shall provide laundering of the asbestos contaminated clothing in the prescribed mennor. This about covers our conversation except for the area caution signs vs must post and the record keeping requirements for anyone working in the area. Hr. Pnuly again stated that they were not giving aa OSHA Plant inspection. He was rot going to check any area but the Joint System Deportment end only for air borne asbeotoo fiboro. Since ho is an OSHA Safety Inspector,' ho did comment on sevoral ltcmo that ho observed but will not report. Such items as our employee lunchroom not mooting OSHA standards, water on tho floor of the warehouse, etc. 1 was led to understand that due to hlo observations we could expect a regular OSHA Plant inspection in tho near future. k / SGP 0006720