Document vVZJbDbJZb1gZg4xNOOn9N6Yq

MEDICAL DEPARTMENT ASBESTOS Medical Aspects, Records, etc. March 2, 1973 Mr. Erich H. Feierabend ' Vice President Brakeblok - Winchester Tou are veil acquainted with the Federal Register and the varioursijfe*irf and health standards contained therein. Recently you asked for clarifica tion regarding the medical program for employees exposed to asbestos. On or before 1-31-73, in the States, every employer is t^eprovlde^^1 available a comprehensive medical examination of his ewop^M tfw ara f exposed to airborne concentrations, of asbestos fibers.f These examinations are to consist first of a preplacement medical examination within 30 days following his first employment in such an occupation. This will not be any problem for us since we already do such examinations before the man is placed at work. This preplacement medical examination also includes a 14x17 posterior anterior chest x-ray, such .as we are making. Suitable inquiry on the history is to be made so as to detect any symptoms of res piratory disease. The one thing which we have not been doing thus far is to include the required pulmonary function testing which, according to the law, is to consist of a forced vital capacity (FVC) and a forced expiratory volume at one second (FEV^ q). According to che law, on or before 1-31-73 and at least annually thereafter, each employer is to provide or otherwise make available a comprehensive medical examination of all his employees who in their customary occupation ' are exposed to airborne concentrations of asbestos fibers. This examina tion is to consist of be least a history paying particular attention to respiratory disease, pulmonary function testing as described above, and a posterior anterior 14x17 chest x-ray. They do not actually mention a - physical examination but we are in the habit of performing these through our survey medical examinations and I feel that we should certainly con tinue with che actual physical examination as well. We are interested in che employees with respect to their total medical health ..id not just their respiratory symptoms and possible diseases related to this system. Some of the malignancies associated uich asbestos may involve other Page 2 MEDICAj- departmen lining surfaces.of. Che body as, for example, che peritoneal cavity, Ic would be*short-sighted indeed co rescricc one'* inquiry only to respiratory symptoms and evidence of,respiratory disease. chink we have to be con cerned mas ^certainly with' pulmonary, cardiovascular and gascro-incescinal problems as such. As of this time. I have instructed Herb Johnson of our mobile unit when he visits any of our plants in the States engaged in asbestos work, to make a 14x17 chest x-ray on each of che employees in che shop who are exposed to airborne concentrations of asbestos fibers. ? Also in che law as I am sure you are aware, there is a furcha^seateoanc ^ chat the employer shell provide os make available within .30 calendar days ? of termination of employment of any employee who has been working ui rh ai ' exposed to airborne concentrations of asbestos fibers, a coi examination which shall, include, as a minimum a chest x-ray, hisl cularly of respiratory disease, and che above mentioned (2) respl function tests (FVC and No medical examination is said to be required of any employee if adequate records show that he has been examined in accordance with these requirements within the past one year period. We would have co have such records, and ascertain that they were sufficient to sacisfy all requirements! add that complete and accurate records are to be maintained by the eap] for at least 20 years. Formerly we had kept such record* 10-years nnlIfo following termination from any cause. Henceforth, we will, have Cm increase^ this time interval to che 20 year span. This 20 year fMcifed hast Bmss fecom- j mended I am sure because of the rather prolonged latent period with respeclf*^ to che development of asbestosis and neoplasms. I would like to interject another comment regarding record keeping, namely, that exposure records both personnel and environmental monitoring, must be kept at .least 3 years. These records, as well as the medical ones, must be made available upon request co 0SKA and NI0SH. You are also aware of che fact that employees do have a right to inspect their own medical records, even those pertaining to their in-plant exposures to hazardous substances and agents.1 1 have been trying since April of last year co obtain on a trial basis, one of che newer pulmonary function testing machines. I kept receiving promises from the 3M Company. In the past few days I was able to receive on a loan basis, a Donti Pulmonary Performance Analyzer made by che Cavitron Corporacion, Model PA-70 Digical. Wc can purchase this machine through our supplier of first aid produces, Karel Medical Inc., for 995.00, plus snipping charges and sales cax where applicable. If desired alchough I do not believe ic will be necessary in our operations, an extra could be included wherein you are able to receive a written read-out of the test. In my opinion, che digital model is quite ample. Page 3 MEDICAL DEPARTMENT March 2, 1973 This machine veighs 13 lbs. and its parenc and modifications of it have been in existence for 5 years which I think provides it with greater impact on the medical public than some of its competitors that have not been in existence for such a long period of time. This machine is relatively simple to operate. One can do 2 or 3 of the above mentioned tests (FVC and FEV. ) in a minute and a half per employee. Having this equipment in the plant itself would seem to be the proper way to handle the situation since one would be able to do the preplacement pulmonary function testing at the onset. Having this done in the hospital, a clinic, or the doctor's office would only involve them away from the job, possible transportation costs, and a higher charge by any outside agent than that which it would cost us with this basic investment and relatively simple training to use the equipment. It would be my recommendation that any of our plants with such exposures purchase such a machine and begin their testing of the employees at this time. . Pulmonary function testing in itself is going to create problems for us with respect to the hiring of individuals and their continuance on the job should they have insufficient or poor responses on the pulmonary function testing. In my opinion it would be difficult for a malingerer to duplicate his malingering accurately and consistently with this equipment because it is so precise. In using this Pulmonary Performance Analyzer, one can easily obtain an impression of the person's degree of cooperation which the machine can largely confirm. '. On page 913 of the Occupational Safety and Health Reporter which was sent by Charles Borcherding not too long ago to each of the Manufacturing Vice Presl dents, there is the following: "(7) The employer shall establish a respirator program in accordance with the requirements of the latest revision of the American National Standard Practice for Respiratory Protection Z88.2, with the exception that no employee should be assigned to tasks requiring use of respira tors if his most, recent medical examination indicates: (1) Forced vita, capacity less than 70Z of predicted value for age, height and sex, or (2) Forced vital capacity less than 80Z of predicted value for age, height or sex in addition to at least two of the following criteria. (a) X-ray evidence of asbestosis (b) Dyspnea (shortness of breath) . (c) Rales (d) Clubbing of fingers " . . If your in-plant working conditions do not require a respirator, this will n pose a real problem. If your working practices or lack of adequate engineer ing requires the use of respirators, then the results of the pulmonary funct Page 4 MEL -AL DEPARTMENT March 2, 1973 testing come into being immediately, as you can see. Those with an FVC of less chan 70Z of predicted normal for that person without additional medical findings, or 80Z with 2 of the 4 medical criteria referred to above, (a) thru (d), would not even bd allowed to work on the job with a respirator. One has to Chink of the maintenance Dan sent in to repair equipment which has broken down. That portion of the shop could perhaps Chen exceed the airborne asbestos fibar concentration wherein respirator was required, thus making it necessary for a respirator to be worn. If that maintenance man's pul monary function testing was not. adequate, he could not be sent in to do the job. This pulmonary f*Mtia|C*0ciA$ chexefexe gpin*. t to maintain mfemiJb times, inso^MdSMp In ftp possible, woefcimj-conditions ~ where respiratitire are not require# am# employees without respiratory deficiency. When it comes to the actual hiring of employees, we will have to inaugurate classes of respiratory impairment. The American Medical Association in 1965 put forth "Guides to Evaluation of Permanent Impairment -- The Respiratory System." A copy of Table 11 which had been reprinted by the National Tuber culosis and Respiratory Disease Association is reproduced. I do not believe at this point chat we should hire anyone in Class 3 or 4 to work in a plant where he would be exposed to airborne asbestos fibers. I chink it would, be still more to our advantage to try and hire Class 1 and avoid Class 2 where we might have trouble with them in later years. We certainly do not want to be guilty of aggravating a pre-existing respiratory problem. I will try and do some checking with other physicians and see what their experience and views might be in this regard. ' . In. the current Feb ru--y lffl3i issum of Industrial Medicine, the*m is a very cicely reference regarding askUrn cos which I am enclosing for your benefit. ' I have attempted to wrift%aiy concerning the medical aspcctm* aor**e*peclally > the physical examination with related tests.* You will hear separately from Charles Borcherding regarding industrial hygiene and safety aspects. ^ ' C. C. Blackwell, Jr., M.D. Medical Director CC3:np Encs. ' cc: C. H. Borcherding, Jr. C. B. Mallory P. C. Milner ' _ M. Pogson* M. C. Rauch, R.N. D. K. Rennie * Milt Pogson: If work practices and/or engineering controls are not adequate, you can see that with the pulmonary function testing that if an employee can' even use a respirator to continue on the job, that he would have to be trans ferred to another job without such hazard of airborne asbestos fibers or sent ' T rhis will not become necessary. It can however create quite