Document vV5zB67V7y462YppLJJQvme4R

FILE NAME: Asbestos Information Association (AIA) DATE: 1976 Aug 1976 DOC#: AIA111 DOCUMENT DESCRIPTION: Memo RE OSHA Statement of Work for Asbestos Standard - Construction Industry / JI iJmS A S B E S T O S INFORMATION ASSOCIATION 1835 K StreetN.W,, Waxhinctoo..C.20008 (202)223*4885 6 August 1976' .Memorandum For.* W3M8EH$ Subject : OSHA Statement of Work for. Asbestos standard construction Industry Enclosed is OSHA's Statement of Work for an Engineering Feasibility Study and Inflationary Impact Analysis for Development"of Standard for Control .of Occupational Exposure to Asbestos Dust in the Con struction Industry. Research- Triangle institute, Triangle Park, N. "S:., has been awarded the contract effective as of August 17, 1976 with assisgned completion dat of January 31, 1977. r t ^ is required to forward its compelted work plan to OSHA by August 27. This paper will be forwarded to addressees when available' . Completion of tasks in the statement of work and "certification" by OSHA is required prior'to promulgation of a proposed asbestos standard for the construction industry. {Notes Different than with the manufacturing standard {general standard), OSHA proceedings, now require an engineering feasibility study and inflationary impact analysis prior to issuance of a proposal.) .Best estimate at this time, without consideration for delays and based on discussion with cognizant OSHA officials, is issuance of pro posed standard in February 1977 with public hearing,following comment period, as early as summer, 1977. Members will recall letter to Dr. Morton Corn, Assistant Secretary of tabor {OSHA), dated July 27, 1976 {distributed by SIA/NA Memo of 7/29/76) reiterated primary recommendation of the Association that the proposed rulemaking on the manufacturing (general) standard be deferred until these proceedings could be consolidated with proceedings for the adoption of a separate regulation for occupational exposure to asbstas in the construction industry. This view Was concurred in by a number of non-members, of the Association in our response to OSHA of April 9, 1976 regarding the proposed revision to the standard. To date there has been no reply to our July 27 letter, however, it has been learned informally that the Association *s recommendation -is now under active consideration. At Directors meeting June 10, it was announced that an Ad Hoc Committee for Construction would be established. The Committee, composed of representatives of AIA/NA Standards and Technical Committee and participants from the construction industry, held ~ PLAINTIFF'S EXHIBIT AIA-128 141073 AIA WL 000020 Page Two an initial meeting August 12-13, Contemplated activities of AIA/NA in connection with .a standard foe the; construction industry will be reviewed at September 3 Board of Directors meeting. Executive Director Enclosure act Mr. G. G. Gabrielson, Chairman, Asbestos Regulation Task. Forc AIA/NA.A d Hoc Committee for Construction RHMV 141074 AIA WL 000021 COLTRACI' J - 9-r~ S -C P 35 POR RESEARCH YRATGLS ESTITUTE ASflSTOS lifORMATIOil ASSOCIATION/. fioriti Axnsrica 1335 K Street, ti W. Suite 402 Washington, , C, 2CCC5 141075 AIA WL 000022 STATEMENT OF WORK FOR AM ENGINEERING FEASIBILITY S T U M AND PREPARATION OF A N . INFLATIONARY IMPACT ANALYSIS FOR THE; DEVBLOFMENT OF A STANDARD FOR CONTROL OF OCCUPATIONAL EXPOSURE TO ASBESTOS' ' ,, t DUST IN THE CONSTRUCTION INDUSTRY > t > 1 141076 ' \ AIA WL 000023 A, INTRODUCTION The Occupational Safety and Health .Administration (05HA) is in: the process of revising the standard governing, occupational exposure to asbestos,. A proposed revision was published on October 9 1975* Due to the uniqueness of the construction industry, (e.g., the multiplicity of nort-fixod workplaces* and the utilization of highly transient work forces), it was exempted from that proposal with the intent that: separate proposal on asbestos exposure in construction be developed in the future. Because of a number of special problems faced in construction^ an engineering feasibility study wj.ch an. accompanying economic inflationary impact assessment is needed by OSHA. The study is to determine, using a variety of control methods, th levels of asbestos exposure which are technologically feasible for the various construction activities, and the economic impacts of attaining and maintaining such exposures. 8. STATEMENT OP PROBLEM 1. General Requirements .. i This study should provide substantial estimates of the " technological feasibility of candidate provisions of a new asbestos- construction standard and estimates of the economic consequences upon the U. S. Construction industry resulting from the implementation of such an asbestos standard. Due to the widespread use of asbestos, a detailed analysis 'of the effect on each aspect of the construction industry is impractical. However, a representative group o'f construction activities where asbestos containing products ace installed or removed should be selected for detailed analysis from available data and reviewed with the OSHA COTR. ! 2. Deliverables Prom Bidders > Deliverables from bidders are defined asti. j a. Work Plan* b. Monthly Progress Reports? c. Draft Report on Engineering feasibility Study; d. Draft Report on Inflationary Impact (bevel 1 or Level 2); ! e. Final Report, ! 3. Per for ma nee:. Measurements *' 4 Contract performance shall be monitored against a detailed work 2 1 4 1-f 0 7 7 AIA WL 000024 plan andi sch.ea.ple which are to be submitted by. the contractor not later than ten.days after receipt of authorization to proceed, Duality of Work shall, be judged upon, thoroughness and objectivity of fact gathering, techniques,, establishment of credentials for. source'data used, logical Construction' and presentation of rationale, as well :&s= the-gnral. management of resources, within established, time and budget constraints, C. BACKGROUND. ON ASBESTOS . 1; Description of Hazard and Health Implications ftsbstbsy used since- antiquity, has; widespread and important applicatigns: in our modern technological society, There are; over 3,000 different products; containing asbestos in daily ,s throughout the til, Si,; The, increasing use of asbestos has added to. the urgency to cope with occupational health problems related to the excessive inhalation of asbestos dust No. cure now exists foe the. diseases caused .by inhaling asbestos fibers. Employees exposed to, asbestos include, an estimated 100,000 insulation, workers, 50,000 ;raanua.ctucing. firm employees,. 60,Q00.end-product users,, and uncounted thousands of construction, ship-building, and auto repair workers. ' , The term M.asbestos* refers..to a group: of fiberous mineral ,silicates;that are highly abrasive resistant, incombustible in air, have high electrical resistivity, and' can be separated into filaments. The present asbestos', standard designates the following minerals as asbstb's t . Chrsdtil.e & mo's'ite , Crocidolite TremoUte; * ftnthophyiiite . e.fclnoiltisv Exposure, to asbestos, fibers, even nonrecurring, short duration inhalation of the fibers, can seriously increase th risk of developing the following diseases .after a period of yearst . Asbest'osis. ~hdnmaHgnantscarring of the lung feissuei . Bronchogenic Cancer -cahcer. ofth lung, ......... ....... ' ;i Mesothelioma." a rare capcer of the .lining of the chest or .abdominal cavities, * 3 14107s: AIAWL 000025 Prolonged exposure may also increase the' possibility of developing, caricr of the digestive tract*. Within the last few years, asbestos has: been, recognized as one of th$ .most hazardous dust contaminants in the workpiece* Because of. tha- wide variety of products and usefs of asbestos fibers, larger numbers of workers ate irt. danger of being.'exposed 'to the'hazards of asbestos fibers. It .had: been established that cigat.tt: smoking increases the risk of developing lung ;cabcef in workers, exposed.: to asbestos. Although- asbestos has. been recognized as. a hazardous substance for many.years, the lack..of environmental data for previous years, and the long latent period for the development of'asbestos^relatsd diseases bav delayed proving the exposure relationship until recently* The scant data from: previous years.-does, not permit the establishment of the dose-response relationship at this time? however- the risk of contacting; an asbestos-related disease is believed to be exposure related* 2. Nature Of th Occupational Hazard . ' *"* Note than .200,00.& .employees face risks from asbestos,'principally^ by Inhaling asbestos:fibers Recent studies have revealed the prsence :of asbestos, fibers in the lungs of. persons having no history of occupational' exposure:, Presumably exposure, was in the area of ship: OohStruCtion or .other work sites, where the atmosphere was contaminated with, asbestos; by spraying operations or other- sources, of asbestos dust. Sme evidence indicates that.-exposure- to an asbestos workers8 contaminated clothing' is hazardous to passers-by and members, -of the- :wofkrs!' family. Asbestosis cass are on record that .resulted from relatively light exposure of a short duration* Asbestos related diseases exhibit no known, early warning symptom's, occurring -as, long as 3Q years after the.-exposure period. Although; asbestos h been known to be hagrdous; for many years, the first cases Pre not redprded medically until 19.00 some 2: years after asbestos production had become large scale* Recent- studies have shown a high correlation between exposure to. asbestos -and deaths caused by asbestos is bronchogen ic cancer mesothelioma, and to some extent other types- of cartder* Researchers are: disturbed that many cases .presently coubterd re, th result of 'conditions relating baefc to. the 19.30*3 Although conditions pf, use. ar. improved today,, uss of asbestos .hav.e; expanded, production has increased, and products are geographically mote widespread. The effects of exposures in the 197,' rc -not b known, until the end bf this century* Exposur to asbesto may occur during any' construction activity- ! 4 1 4107$ AIAWL 000026 whet asbestos-containing products ace either being installed or removed. In the construction, industry, these products includer i Asbestos cement pipe acid Sheets? ; Vihyl asbestos floor tile? , Sheet vinyl .flooring; Roofing papers?, Packings and gaskets? . Insulation pipe, .and thermal?. Coatings and compounds?' and , Reinforced plastics.: COhstut.i'ori activities that hive the potential to release asbestos fiber re sf#wi/9f cutting drillings grinding?, or otherwise handling of these products.. Since asbestos has'been used, in building m.itefials for many 'years* it should be rellfd that in building demolition, renovation? and. remodeling.? the worker j_s an will continue to be exposed/to 'asbestos fibers.. [3i standards in.,force and Proposed Ah lasbesfe.s standard of 12 f ibers per milliliter greater than 5 microns in length or 2 million particles1per cubic foot of/a.ix was. .included in the initial group of .OSHA standards published; in. the goderai Register on May 29, 1971 (36 gR 10466) It was derived from an established Federal standard, promulgated under the Malsh-Haafey Public Contracts Act- or? May 20 1969,,. An emergency temporary.standard for occupational, exposure to asbestos dust, was published in the Federal Register,,oh; December: .7? 1971. (3.6 FA 23207). It. limited ^xpbsuT^hTTIowiT""!^^ 8-hour timeweighted vrag air born\.co.nc:.ntsatio.n. -of ashes tbs. dust to which employees a.e exposed shall not exceed 5'.fibers"'per milliliter..greater than 5 microns ih length* as. determined, by the mmbcn...fiber method at 4,-4.50x:magnificatidn; (4- niillime te r objeqfcive) phase contrast; illumination. 'C.O'h.centrati.ohs above. 5 fibers per milliliter but; npb t.o.:exceed lb fibers; per milliliter may be permitted up-to a total/ of 1.3 minuted in an hour fot .up to. S, hours' in art 8-hour day." } Or? danudry 12 1 9 7 2 , a proposal for an asbestos standard, m s pubiishe.rj in the Federal Register (3? FR 466).;. ffts pC.DOS ihcludsd tile emergency temporary standard >nd. .additional rules on subsidiary issues. After receiving recommendations from th National Institute for .Occupational Safety and Health and the Standards Advisory Committee 141080 AIA WL 000027 on Asbestos In February 1972 and holding public hearings on the proposal in March 1972, the present standard was promulgated June 7 1972 (37 FR 11318). The present standard established an 8-houc time weighted average (TWA) concentration exposure limit of 5 fibers longer than 5 micrometers per cubic centimeter of air with a ceiling limit of 10 fibers which became effective July 7, 19?2, and a 2 fiber TWA limit to become effective July 1, 1976 By way of introduction to the proposed revision of the asbestos standard, published in the Federal Register (40 FA 47852), OS HA has stated t *This standard, as revised, would continue to apply to all employments covered by the Act, but would exclude the construction industry. It is OSHA's intention to develop and propose a separate revision to the existing asbestos standard which would b applicable only to the construction industry.*' . This study is intended to provide essential information for. th development of a special standard for the construction ind*ustry<s. D, ANALYSIS APPROACH ' ; 1. general Methodology In the organization and performance of this Task Order, the contractor must recognize the importance of an interactive,* relationship with OSHA personnel to facilitate timely and effective achievement of the goals. A detailed methodology, developed in the farm of a specific work plan, shall be the basis for the conduct of this effort. Further, the contractor shall assemble and identify a highly experienced interdisciplinary and multidisciplinary group of professionals to accomplish this task plan. In the course of conducting the engineering feasibility study and inflationary impact analysis, the contractor shall structure an adeguate data base upon which to substantiate those results* This data base shall reflect all published and available data sources relevant to the analysis, including all data collected by OSHA personnel, as well as technical, governmental, and industrial publications not previously surveyed. Of special importance will be material collected in support of recommendations of OSHA's Construction Safety Advisory Committee and literature obtained from the Environmental Protection Agency on asbestos which was collected to document SFA's regulations on asbestos. Further, additional data, essential to the substantiation of these results, shall be obtained by th contractor as required,.* The engineering feasibility shall include an assessment of a'wide tapge 6 141081 i ' 1 AIA WL 000028 of construction industry applications of asbestos products. Minimum feasible asbestos concentrations shall be reported based on factual data and professional engineering judgment where appropriate. This analysis will include the type and level of control effort nefeed to maintain these minimum concentration exposures, personal protective equipment, etc. Additionally, the feasibility of requiring medical surveillance, retention of medical records, and monitoring records similar to those requirements for other industries (Ref.s Federal Register, October 9, 1975) shall be evaluated for the construction industry. The inflationary impact analysis shall consider the most feasible and cost effective remedial approaches required to comply with these minimum levels defined by the engineering study. While it is vital that the anticipated cost of compliance shall be discussed, it is equally important that the >'~onomic ramifications of those costs be considered, in the latter case such direct issues as the financial constraints related to these cost burdens must be considered. Moreover, it is important to address both the primary and secondary effects of incurring these costs in the various sectors of the affected commerce. This consideration must include at least the effects upon employment, productivity, supply/demand of critical materials, market -structure, and energy consumption. ,, 2. Identification of Specific Sensitivities and Areas of Invited Recommendations """""""" ' ' " ' '' '' In performance of this Task Ot dec, the contractor should indicate the level of confidence and uncertainty in all areas of analysis. Any economic dislocations should be specifically highlighted. The contractor should review marginal construction sub-industries to determine disproportionate impacts. Certain resource constraints of administrative aspects of standards compliance should be analyzed. With only 3500 certified Occupational Physicians in the United States, the burden of the medical surveillance requirements of the- asbestos standard upon the medical community must be assessed in light of other potential demands for their services. Additionally, the specific burden of keeping records on and reporting asbestos exposures must be analyzed and recommendations must be presented. The general availability of technical capabilities and equipment necessary for environmental monitoring of the workplace, as well as that of engineering control equipment, must be assessed. Consideration must also be given to any specific conflicts or complicating factors presented by other standards, rules and regulations promulgated by QSHA or other agencies, 3. Task Platt ' In carrying out this task order, the contractor should follow 141082 AIAWL 000029 th sqehc ofi: tasks identified in exhibit 1,. to the extent pbs-slb-l.i Th contractor .should initiate, the-, task order By m'ting with- the OB'dh Project Officer, and other OSHA official's to adduce a .clear understanding of; pSHA's specif ic needs and; to gain. a. broad 'OverView of' the. pcojt,Ine ludi rig: majo'c assumptions, limitt ions, and the timetable for complet ion.. Agreement should be reached, on report contents', frequency# arid, th m.chan.isms:of the review p'r-cssi The contractor shall analyze the oyepali skill requirements needed to: conduct, the project and develop a highly experienced: pcoj'act team with ,appropr iate ihfc.rdi.scip.l.int and. .multid.iscipl.inery sk ills. ;0n or before ten calendar days .after, receipt of authorization to. proceed with this- task, ordec i the, con tractor shall provide' a step-by-step description of the. approach ' the. task order with detailed schedule and., staff ing plan. This workplan should b .'iti such detail that OSHA will be, able to evaluate; the methodology .and the contractors'- understanding, of the problem. It should be segmented into log leal i phases'With appropriate' timing and mriToihg.'estimates fed as to h :sitbie:- for use as a tool for meaucm.nh of- the, project's plogress> ! The work plan should also show the division of resportsibilities between | the economic contractor and the engiheeting sbco.atra.cto to b engaged in the study. The :.propofeed workplan and project staffing shall?be reviewed and approved h:the OSHA CQFU: - .4.. Ta skDescriptions; ,- The following is a brief-description of the efforts to be carried out under each tasks * Task A - Collect Information: A review should be-made for all- literature: and materials available from OSHA. (Including reommendatia.rts of the Advisory Commit tee on Construction Shie-fc dnd. Hehlt.hi:r, EPfty :and other governmental and industry saureds discussing?; OSHA abbts standards Urtcludxbg 8- herap TWA. limits# ciiiriga# rcord ksfeplrigi .traihhgv medicai/hv.lronmh.bal srveilllhee requirements, .and engineering!- controls) # febesto^flafcd processes aft# the like as well: f- -EPA - Background information Ort. National Emission Standards- for. -Hazardous. i Air Pollutants and E M Development Documents* , Indifiuals- ahd brg&bi dations: concerned with asbestos exposure ..ih. the construction industry should b:.contacted and: existing files, built up b y these: patties- should\bV examined, .duth parties include; j ,, OSHA and' NOSH personnel? Selected- members of the Advisory Committee, on .Construction Safety: arid Halth (Asbestos subgroup),? .i Construction Industry Associations? I- * 8 141083 ASA WL 000030 * Construction. Trade Unions?: EPA personnel? ' Asbestos Information Association of tfotfch America? -. Municipal Health Author ities. Documents tlvnfc to asbestos, exposure in the cons true'fcio'ti industry should be 'collected. Also# information needed, to make Level 1: Inflationary Impact Sbafemrtttshuld :b; collected*- :Sjch information might, irt.elde industry Arthbal .Repotts/ CWsuk &ta> h.d Trade. Journals. Task B - Identify Sources of Asbestos- Riber Exposure Present and possible future sources of asbestos exposure in the construction industry should be Idgntified. Some of the major sources of exposure are found In the following construction processes or segments of the. construction industry? o Installation or removal of asbestos pipe covers-?. *_ Dry wall applications; & Remode ling/demol it ion t, Construction of power stations? . i 'i Boiler E-opm. construction l These- and: other construction trades where workers are exposed to.: asbestos should be identified and quantified in-such gfoapi.ngs as;. (i) constant exposure to asbestos (Ji) intermittent, exposure to asbestos i i i i i i incidental exposure to asbestos A .thorough review of previous studies, contacts with governmental enforcement officials,- and' review of. monitoring data and select field studies should be .ndtfcaks.ni Th particular Construction operations which emit fibrous: asbestos, should be identified in terms of b t t i the level, of concentration and the: degree, of exposure Iby}. Operation or class bf. worker;). Task G - Estimate Number of Workers Exposed; bevels, of,Exposure The construction industry employment associated with various i i 1 ' 141084 ; * AIA WL 000031 levels of. exposure to .asbestos fibers and various fiber ernItfcing operations should be .estimated. This should. be carried out through a variety of'contacts with industry,, Unions* governmental agencies, health researchers, and other parties knowledgeable about asbestos exposure in construction. Workers who ;do not handle .asbestos, but vho ate exposed due.to proximity to. Omitting Operations should also; be identified and fch'feir exposure levels noted. Additionally information documenting the transiency of: construction employment? range of employment' durations? turn-over rates? employee mulii-e.mpioyoc exposure?, seasonal variations? etc., should be developed, Corcfeiatlah levels of asbestos exposure leyals/d.urfciohs with specific, trdes/occupatLons should be obtained Task 0 - Analyze Effectiveness of Current Controls The. effectiveness;.of strategies ourt'ently being used to control : asbestos'exposure in the construction industry should be.1exrttined,- j The current control methods to be examined includes ' | Substitution? ! ; . i i Local exhaust. - hood; with vagUhm? ' t , Work practices?. we'fefcing down? * vacuum tools? personal protective devices? ; ** respirators? t* wOxk clothes: f ; ` ) This task should be accomplished through the coopefati.bn. of construction companies, and th. use Of certain field studies, also, federal enforcement, -agencies (e.g?? osaa and EPA) 'and municipal enforcement agencies .(lie, those in Minneapolis, Chicago, and Philadelphia) should, be, contacted., Special attention should be; paid to EpA's experience iri regulating asbestos emissions at demolition ! sites. ' j The .effectiveness of. current, caritrol me sures with regard, to reduction. Of exposure levels as' 'Well as other factors such' as cost. of. achieving reduced exposure, workee acceptance* long term . practicality,, changes: in worksi productivity ;.nd other factors should b'e:.addressed. i 10 tMossi j AIA WL 000032 Task E r Propose Alternative Control Strategies Alternative control strategies should be proposed for the construction industry to achieve reduced exposure levels comparable to those levels proposed in the general industry standard (0.5 f/cc -hr TWA limits). The control strategies associated with 2 or 3 alternative exposure levels should be considered for this task. The response levels should be specified and the control strategies to meet these exposure levels should be determined. However, there might be exceptions in certain operations of the construction industry where it may only be possible to determine feasible exposure levels based on existing' and available engineering and other control methods. Asbestos engineering control methods in use should be examined in terms of their applicability to the various exposure situations found in the construction industry. In addition, all experimental control methods being developed, e.g. John Mansville's portable power tools, should be investigated and evaluated. Patent searches should be made. Foreign experience should be evaluated. Analagous dust control systems should be investigated, and their applicability or lack thereof should be explained. Wet fabrication, regulated fabrication areas, pre-fabricated materials should be discussed 'using all available data based on real world experience. work practices that enhance or complement the effectivenes of engineering controls should be identified. Practices working with other substances, or in analagous situations (e.g. shipbuilding) should be examined for possible extension to asbestos work, foreign and domestic experience should be explored. Particularly significant are work practices suitable for use in demolition. Whenever possible actual data should be used. Exposure monitoring schemes should be examined foe applicability to representative construction work situations. The issue as to whether many of the alleged variables in construction (e.g: non-, repititive tasks and exposure to the elements) negate the effectiveness of any scheme that calls for monitoring on a less than continuous basis in supplying projected .estimates of exposures between monitoring should be examined/ This would lead to an identification of the kinds of representative monitoring schemes which would work for the construction industry. When considering medical surveillance, the additional problem when dates of periodic and pceplacement exams occur randomly among employment periods of the transient work force and the related problem o medical tecordkeeoing should be considered. Statistically, what are the chances that'certain kinds of construction employers will be hit with medical surveillance or recordkeeping burdens unrelated to 11 141086 AIAWL 000033 their employee population or to relative employee^exposures to asbestos? Other ancillary requirements include change: rooms and sanitation facilities and should be discussed in teems of prototypical and representative construction work situations.- Actual data should be used to the. extent possible. Task F' - Analyze Alternative Strategies Each aspect of the alternative proposed under Task E should be analyzed relative to a full set of relevant considerations, to inclut Effectiveness in reducing asbestos fiber exposure; . Cost of compliances ~ Capital; - Operating and maintenance; Energy; ' Ancillary (monitoring, medical surveillance, record keeping, etc.) ; 1 Consistency with hierarchy of controls (OSHA); Wotker productivity losses; i v. Adoption of substitute materials (functionally similar, hazardous in use, more expensive, etc.). ; .f Task G - Screen Inflationary Impacts ih Lve! of IIS Required An approximate estimate of several relevant alternative provisions should be made: to determine whether an IIS will be required. Such estimates should be made for each of:'the alternatives proposed in Task E arid analyzed in Task 5?. Task a - Analyze Health Benefits. Potential health benefits associated with exposure levels identified in Task ? should be examined. All relevant information on health benefits should be utilized in this task. The record developed on the proposed general industry asbestos standard id expected to provide additional information on health benefits which should be incorporated. : Task T - Prepare Draft Report on Engineering Feasibility Study 12 ` 1^1087 AIAWL 000034 A draft report on the results of the analysis of Task f , incorporating the results of Task H on health benefits should he prepared. The report should provide both findings on the various aspects of the analysis and recommendations for a proposed OSHA standard on asbestos in construction. The basis for the recommendations must be thoroughly documented. Task J * Collect Information for Level 2 IIS In case an IIS is required, the contractor shall collect whatever additional information is necessary for the more extensive report. Task K - Prepare Draft Report; Level 1 IIS In case an IIA would suffice as determined in Task G, such a report should be prepared and submitted to OSHA for review. Task h - Prepare Draft Report; Level 2 11$ In case an IIS is required as determined in Task G, such a report should be prepared and submitted to OSHA for review. 'This report shall include, but not be limited to, the following; , Compliance Costs - The compliance costs quantified iq Task F including "engineering equipment costs, implementation cost, energy cost, administrative control cost and the like; Indirect Costs - The financial costs of compliance effected by cost b"capital, cash flow, depreciation of equipment, etc.; * Energy In terms of STO's, the change in energy requirements resulting from the most eost~effective engineering controls identified in Task. F. Consideration shall also be given to the change in energy requirements resulting from the possible utilisation of alternative substances in the process stream, variations in specific process rates, or variations in end product process manipulation. 'Examples of these variations ate changing processes, substituting process materials, and modifying end products. . Critical Substances - Certain substances have been placed on a list of critical materials by agencies of the Federal Government due to their importance to the security of the Nation. Asbestos is one of these critical substances. Asbestos is utilized as a raw material in the production of critical materials and in this respect has an impact on the supply of critical materials. This potential impact shall be evaluated. { Employment - Compliance with asbestos standards might Jjave 13 141088 AIAWL 000035 significant financial effects on construction operations, resulting in significant changes in the size of the work frce. Several significant factors which might be found to influence employment intlcf.e: ; - Construction sub-industry being forced out of business Modifying work practices or construction activity, anc Force substitution of alternative substances* ; Productivity - The implementation Of alternative controls and work practices, may have an impact: on construction worker productivity. In other words, to evaluate that impact, a good understanding of the construction activities involved with asbestos materials, and implications of new practices and controls must be obtained. Factors which might influence productivity include: - Engineering controls hindecing operations; Personal protective equipment hindering employee ' movement; * - Less efficient alternative process; - Medical surveillance implications with .respect to productive manhours. ,, Market Structure - Examples of the types of changes in market and/or industry struefute that this analysis might identify are: - Smaller firms going out of business or consolidating, producing monopolistic situations;. i - Significant price increases affecting supply/demand relationships; and " Firms choosing to manufacture alternative products affecting supply/demand. - Control methods affecting product quality and, itvfcu.cn> product acceptability, e.g., wet processing of textile! Ii* developing this economic analysis, it is essential that the: contractor produce reproducible rationales for determining the economic impacts including idanfciication of variables, associative relationships, choice of surrogate measures, and levels of uncertainty or confidence. - 14 489 AIA WL 000036 Task ;h ~ Prepare Final Report After; receiving1 written arid oral comments from OSHA, the contractor should:revise the previously submitted draft reports and Combine them into a single document for publication by OSHA, if desired. The. report shall contain a logical presentat ion of the dabs, basis, the methodology utilized, and the results of the component analyses including sound professional judgement. The Engineering Feasibility Assessment shall provide detailed methodologies, alternatives evaluated, and recommendations relating to the engineering feasibility of reducing asbestos exposure to minimum levels during construction activities. ! 15 141080 f AIA WL 000037 SCHEDULE The following deliverables from the Task Order will be completed as noted. Resort Due: .Oral Progress Reports Written Progress Reports Work Plan Draft Report on Engineering Feasibility Study' Draft Report? Ilk (Option) Draft Report? 1X5 (Option) Final. Report Biweekly Monthly Ten days, after 120 days after authorization authorization 120 days after authorization 135 days after authorization 165 days after authorization 141091 AIAW L 000038 ItWrti'ttWffklW'UKl'l fr EXHIBIT 1 Flow Diagram of Efforts Under the.Task Order AIAWL 000039 i .a** i U . M.<... .-"i n !i. * oy.Xh :u X:: '-tx co::n?;^;cT.tfv r: . This is to initiate T-.tah 2: ilobsstcs Oust in U'.o Construction TniUTtry, pursun.it to the Depart:.->nh of ..'hot Cor.tr.-.ct n~0-F-dC035. ; tusk is g-.-r.vrislxy dts O'*- '-.tor x e'.ii of one co-> cjuixcie rur-cnr.*.:1 Inflationary ir.poet .-to,t e r m .ttsthodology. SCfSCm The following deliverables for as no feu. T ask Order w ill be completed ksrcrt DCS * Oral Progress Reports * `.icizrar. Pro.jrazs Reports work Plan * Draft Report on Engineering Feasibility Study " Draft Report; IIA (Option; * Graft Report; 1X3 (Option) -> tiT.il Report Biweekly Monthly Tan days after authorization 120 days after authorization 120 days after authorization 135 days after authorisation 165 days after authorisation Xtra Xs?a gurthasad xr.z billed rr-iir Direct ..'tits Ail aonputer proyracts and operational OCt* used by ?.TI in support of Task Order 2 * File description of all ester files and working storage files 165 days after authorization 165 days after authorization 165 days aft". ...lorization 141093 AIAW L 000040 The followin'! ^.Yr%iuatC'J<-V :>u:'v?r..s'.ss- the total oontrautr' estimatiti coAt .co.' U U s r?" .;i Ceo*.' On r-lcaxtt. ind- s c v - J o t t-ji-a -contrae pap's ''-l''Ut'l 'rrjv p. ir,. -Ih'bb-- '-ours ..cd pronoii-efr. sfb->uil 5<Vf ^sy$'>**--`.nB( * .e..-1-; 'hi ;.,r.id.- I-ib Ob' Co.', hi? I.-abor Cataper" Project Director Rata $41,83 X- Hours 324 Total $ 21-,'945 Senior Analyst 35.94 27.05 75.5 2,652 3",942 -27,927 .72,007 $121,079 Direct Costs. Comotr: Charpas (WCC) '4->.0 hr. Economie.- Datei/ Cotai -Direct Costi Total rsi> criar C-'tt ?72S/hr .1/ :-2,90'4-' hm : $127,808 pi;rtvt.i.aicr: :ay.ftr.3'3'. Util, be billed as -specifled in the Department- of Labor; h&.r Direct C0 Sts-listad above \?ill be billed as indicated. Additions .Any computer services costs lit. excess, of 'th amount stated iri this'task order will not be accepted by OSHA without-prior: written Justification from RTI and approval by OSHA 1 1 / I n c it id a s ^-TU X3M 3 ?0 /lfi.S $6C)0/hr. + $60 O'.iSE: (G5A) + $66 f e e 2 / I n c l u d e s $ 2 ,5 0 0 p u rc h a su p r i c e ( $250 OMAS. lGOA) + $275 f e e AIA WL 000041 Sg nlot' .1y% 1 si. r.-'c3 s?..J7ir i..al7-t D'., jchasioh aiyst. H .C . Wright A3HO5,X2TX0:t >o *h%;?.yojv*i#osj3 *>$' t?H: Dos'rtssn't. .stb: Co'itvt J-9-?-0C3'3> this tocun ar.fe cens Sif.uia.s 'a fully i&MSps.tct "ras-tv Oris-;"" issisi; ssr the statement.-of ftosei. thszei.;; ati t s tv-re in spe citisi- ani riaiine. Xila?r the cor.iifi<?n s&a.ciEii'd tiers-in this ?as>; Order is re.a- io.r iiBfcw:tftti'psv, .-'I-'" * .5vii- '?. .3*11 Cottrii-iihg Ofiter *s' iacbfloal h.errisshtati've 03:-:.-. V -, . ; : X Data ?.a search OjriangXe Institute ".......... ...... ...... -- ~-- " i 141095 AIA WL 000042 i i i 141096 AIA WL 000043