Document vV1jp5qp4JwO6arZwMQnM2gp8
Hr. X. C. Bylan rm Wayne
V. yasauliotle
Safety & Security, M.T,
//
October 29, 1974
Maaira. C. F. Bleo J. r. Cow A. F. Rarcer
ASUSTQSSIBMABT
Attwhad la a redraft of your ivnarj report reviewing the current etacue of aabaetoa expoeure* la our plaata.
Although your lateat draft included a niaabar of euggaatloaa dtaeuaead ac the seating of May 31, 197A, additional chaagea have been Incorporated la our rewrite (aapeclally the flrac aeveral pagee) to nore clearly define the probLea, prograaa, atatua and requlreneata for saetlng 1976 criteria.
To expedite the final draft, unlaas there rasala aubataatlal dltferencaa In context, we ahouLd be-able to raeolve any further ehangee by phone following your review.
Also advlaa If Corporate engineerlag haa provided or will provide any input for this report, aapeclally la the area of capital expenditure* for seating the lower fiber level requlreaenta.
W. Faeaullotla
V
MMtSII-141 *! 1
nteroffice correspondence IAS CorpouWon
OCATION
mow
.OCATION
REVISED DRAFT
oat* October 29, 197<
STATUS REPORT - ASBESTOS EXPOSURES
l. Background
The handling, use end storage of asbestos fibers at a number of CAT plants necessitated the establishment of a comprehensive sampling and monitoring program as a result of federal regulations aimed at limiting employee exposure to this substance. During 1972, this program wes directed coward the aceusiulation of a body of data for the three-fold purpose of attemtping to determine the following;
1. The number and identity of Job classifications exposed to levels
of asbestos above the OSHA established end proposed future threshold
limit values.
2. The current levels of asbestos fibers at particular job locations.
3. Engineering controls and capital expenditure requirements to reduce exposures to acceptable limits.
In 1973, the monitoring program was modified and directed towards obtain ing time weighted average (TWA) and peak exposure data on a specific list of job classifications which the previous program indicated a potential for excessive exposures. This program required a minimum of three TVA's and three peak raadlngs during the year to establish exposure levels in accordance with regulatory requirements. To eld in this effort, individual locations were provided with sampling equipment and procedural instructions to supplement CEED activities. Unfortunately, the actual total data thus produced fell short by approximately sixty percent of the total number of data points anticipated.
However, the 1973 - Ik and the previous monitoring sampling programs revealed several variables which contribute to the difficulty of placing a precise level on a given job classification. Individual and group work practices, housekeeping efforts, weather and seasonal variations, efficiency of dust collecting and ventilating systems, maintenance practices, employees' physical stature and the particular product being 'made, all Influence fiber-exposures. In-addition, variations An-proccss equipment, plant layouts and production activity contribute further towards producing varying fiber counts for the same Job clesslflcatlons within similar product group plants.
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Taking Into account the above variable* and the limited number of replicate samples conducted during the 1973-7A period, an estimate of the nature and Intensity of exposure to esbertos csd be drawn If all data collected to date Is utilised and an assumption Is made that samples are representative of the employees' dally, tit* weighted average and/or peak concentration exposure*. These results are being compared with the 5.0 fiber/cc TWA and 10.0 flber/cc peak exposure limit* currently In effect and the 2.0 flber/cc time veighted average exposure and 10.0 flber/cc peak to take effect In July, 1976. Current Indications are that any revised asbestos standard will not Include a lowering of the 1976 threshold limit values.
The attached data sheets summarise the results of the various sampling programs. This data is broken down by group, plant and operation.
. Asbestos Cement
1. .SUIul
____________
_________
_____ __
With reference to table #2, pages 9 and 10, the following points are evident;
(a) Unde; current operating conditions, housekeeping and work
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practices and maintenance schedules,, the possibility exists that the 10.0 fiber/cc peak celling concentration nay occasion ally be exceeded on the beater decks,during the disposal of scaap, unloading boxcars, and the emptying of dust collectors.
(b) .Tests have not shown the current 5.0 flber/cc time weighted average limit to be exceeded In any of the areas where asbestos cement products are made at St. Louis and South Bound Brook.
(c) If plant conditions remain unaltered, the 2.0 flber/cc time weighted average exposure limit to be Imposed d .ring 197b may be exceeded on all beater deck job classifications, m addition, the rework handling on the beater deck and boxcar unloading at Mobile could also exceed this fiber limit.
(d) Corrective measures to reduce fiber levels at the saw operation In St. Louis were effective in achieving the fiber limit scheduled to be Imposed in 1976.
2 . Discussion and Recomendatlons
The goal In the asbestos cement plants Is to consistently achieve less than 2.0 flber/cc time weighted average exposure on all Job classlflcations on cbe beater decks and rework handling and to pravant exceeding the peak celling concentred z r, of 10.0 flber/cc oo Che beater decks, rework handling and boxcar unload ing.
The adoption of work practices.such as chose listed In the floor Tile and Sheet flooring section of this report should significantly reduce the potential for exceeding the 10.0 flber/cc peak exposure limit during the unloading of asbestos fiber and ocher areas where asbestos Is handled.
In order to bring the beater decks Into compliance with the standards scheduled for 1976, the following suggestions are submitted:
1. Every effort should be made to clean, by vacuus, the heater decks and the surrounding areas.
2. Work practices concerned with the handling of asbestos should be Initiated.
3. All existing dust collecting equipment be pieced is design
working order.
following these three prerequisite steps, locations would be resurveyed by CEED to determine the exposure levels achievable 'with 'existing equipment. - After a thorough evaluation-of these results, recommendations for further improvements would be made. Because of physical differences, the three beater decks would have to be treated separately, but the same principles may well apply at all three locations.
Laboratories
(a) South Bound Brook
The operations that have been texted at thlt laboratory Include fiber fluffing, cutting corrugated sheets, and cutting Stratollte elding.
The cutting operations gave results of 20.9, 20.6 and 10.4 flber/cc on samples taken for 10-12 minutes. 'Since these values-were obtained,.adust colleetingsystea has been Installed which ahould eKainate any problem. Confirming samples have not been taken as yet.
V. General Conclusion This report contains suggested work practices and Improved housekeeping mechods. Oust collection systems are also recommended. The lmplementatlon of the above vlll initially lower fiber levels. However, the.'/ suit be constantly supervised and maintained If we expect to keep asbestos levels below current and future standards. The following practices will help to maintain the regulated levels of asbestos. 1. Each plant should adhere to an annual monlcoring schedule lor Job clsssiflcatlons subject to asbestos exposure. 2. CEED should monitor these same Job elesstficat1ons on an annual basis, calibrate the plant's sampling pumps and Insure that their equipment Is in proper working order. 3. Plants should establish and maintain a periodic cleaning and main tenance echedule for all dust collecting systems to assure their operation at optimum efficiency. 4. Plants should continue the eupervislon of accepted work practices and the maintenance of good hygiene conditions In order to minimize and control the effects of any existing dust exposures.
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