Document wDed2b0b0ZV3Q59VEo9JY2XNo

& JLiC^MPANY CORRESPONDENCE **9*(R(R.v. 1-6S) (6 c" ' '> C.- i' 'j ' O M: T O: COPY: DATE S SUBJECT: Ronald E. Benton - Industrial Hygiene, GOB E. B. Thompson - TILO F. J. Piccioli, J. Link, J. W. Wright - TILO; W. A. Wright, J. R. Amos, R. B. Newman, Dr. J. M. MacMillan, Dr. E. C. Irby, Ruth Carson - EXO; B. J. Sasser - GOB September 9, 1976 INDUSTRIAL HYGIENE SURVEY - TILO PLANT 'August' 24 & 2b, 19/b During ny recent trip to the Tilo Plant in Stratford, Conn., I discovered two areas where several bags of asbestos were stored. (Mr. Jim Link is aware of the exact location of the areas.) The housekeeping in both areas was extremely poor, as evidenced by loose asbestos accumulations on table tops, benches, floors, etc. Ihe asbestos is mixed by hand with water to form a paste, which is then applied to pipes as an Insulation material. The paste is not made dally, however, but only on a demand basis for patchwork on existing insulation. As a result of OSHA's increased attention to asbestos and the severe health implications of this material, I feel a re-evaluatlon of your use of asbestos is necessary. In light of this, I would make the following recommendations: , 1) Immediate clean-up of all areas where asbestos is used or stored. All loose asbestos should be removed with a vacuum source and collected in an impermeable bag. This bag-should then be sealed and disposed of in a sanl&^3andfill. All employees involved in the clean up should be issued 3-M #8710 disposable respirators and ooma type of disposable coveralls. This equipment should ,#$laced in a sealed impermeable bag after clean-up and also disposed of in a sanitary landfill. / Discontinue the use of asbestos for repair of pipe insu lation, as well as any other applications. All asbestos in stock should be disposed of in sealed Impermeable bags as outlined in recomendatlon 1. Evaluate the feasibility of substitute materials. TVo possibilities are: a) A rigid fiberglass Insulation. Available from most any insulation distributor. w .. , ... RMC0800280000355 E. B. Thompson - TILO -2- September 9, 1976 b) A hydraulic setting cement from KEENE INDUSTRIES, Princeton, New Jersey, 08540. This is a non* fibrous material which is made up as a paste. In the event Tilo decides that continued use of asbestos is war ranted, I should point out certain parts of the OSHA asbestos standard which would require immediate action. They are: 1) An Initial Determination - "Every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine whether every employee's exposure to asbestos fibers is below the limits..." (the remaining requirements are necessary, regardless of the as* * Ibestos exposure level: 2) Sampling Frequency and Pattern - Samples shall be of such frequency and pattern as to represent with reason able accuracy the levels of exposure to the employees. This has generally been interpreted to mean sampling at six (6) month intervals. i 3) Clothes Lockers - Provide two (2) separate lockers or containers for each employee, so as to prevent contami nation of employee's street clothes from his work clothes. ? 4) Employee Observation of Monitoring - Give a reasonable opportunity to affected employees or their representa tives to observe any monitoring. i 5) Caution Labels - Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their con tainers. The caution labels shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: CAUTION Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm RMC0800280000356 E. B. Thompson - TILO -3- September 9, 1976 -7 6) Housekeeping - Maintain all external surfaces free of ac cumulation of asbestos fibers. Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos contami nated clothing consigned for disposal shall be collected and disposed of in sealed impermeable bags or other closed impermeable containers. <i 7) Recordkeeping - Maintain records of personnel or environ mental monitoring for at least three (3) years. Employees and former employees shall have reasonable access to these records. a 8) Medical Examinations - Provide or make available, at employer's cost, preplacement, annual, and termination medical examinations, for every employee engaged in oc cupations exposed to airborne concentrations of asbestos fiber. This examination shall include as a minimum a chest roentgenogram, a history to elicit symptomatology of respiratory disease, and pulmonary function test to include forced vital capacity (FVC) and forced expira tory volume (FEV) at one second. Retain for at least twenty (20) years all medical records developed as a result of this standard. Contents of these records shall be made available for inspection and copying to certain authorized individuals. In the event results of a monitoring program indicate asbestos con centrations in excess of the OSHA standard, and the plant continues to use asbestos for repair of pipe insulation, additional require ments will be necessary, in order to ensure compliance with the federal regulations. I have enclosed for your information a copy of the present OSHA standard for asbestos. I should also point out that OSHA is considering lowering the present standard from 2.0 fibers/cc to 0.5 fibers/cc and labeling asbestos as a carcinogen. This would necessitate considerably more recordkeeping, personal protection, engineering controls, and monitoring requirements, than the present standard. If I can furnish any additional information to you, or be of any further assistance, please feel free to contact me at any time. REB/mm Enclosure Ronald E. Benton RMC0800280000357 I1910.1001 TBit 29--labor Tam 14-ttma Du OrtfnM Hpprf* Ut/*P CnitiBkaK Qaarti (raetabM 0--11 (Ml<aO. OMahaBUc CaMtk* tw ealenlwcd foa tl MO' AncWa SOrf< UglOrt-t MlSP WhOH-t TtGnSi* Cm H lUM wteililwl from a loralt-far govts lMipk(a.lacMta|Mnl SOcsUi Omi Oa t% y tslllnasUka) %SI0. nk(MMiM Ini T_rbttHtb.m. l On i ` ,, . Tmimnn UM, flbrast) hnlud tfom..______ COrwaTpttdiail;htt*a*ta(IM<m%uvarlnaiOKl)iI_)*._.t_.r._t.r_.l_.la._a._. i tbaB%nOi____ Inn ar Nnbai____ laptaMataaka, TaU la ---- l.ttnsW ar Oni/lP %8iOrH SagdW HOCISO pNpoanO-dCUaoaTnPlltnttaono hpartnalncka par cabia Mater ___ -sarttelMPvtx. bapHinUeaaraaaamacpntaaratalHoaniitrdp*hr rcSsb(bMtoMsdt alalcabinr.kbsa. std aa 1 Tha parcruac* o( crrstalUnr <Ulea la (ba tartaola b tba aoMOM dattrolart boo ab-barw maipln, a> aamaalaa (babanaInarotauenaebeltal.a obkb atbar aaibada ban baaa Aa MaiMMb (ba aambnaa Ibar snood al XMaa eaotran maenHInitoo ntlaBaaothl IrbaboUctnntitniUnoun alanddnanmnaalwt gwul bruanbUr tlrbbaaadMleba paadnt a la...tactnr wh thr kJWvtna diaranarUka! ftoolatntns < 1% fiUj If > l%qaaita.SMgaifU AiSvMMh (Iiiism (Bsaamir uMm 1 as as at hmiristmMm v m n m u9 ItoatoiiisviimstosalirOto aata nbr la dM an* aa ABO laiiraaialjr M irtptoalila bactlaa a( aaal dovtotonrlMSoliAsMBCIAaSfaanvTMO--tlng bbalalUlbWbarlaUrb>MlMaMII|M [M m mot. Jum ST. 1974. Hartailrnafit bad imanaad as to IB OQ7S, suj M. irraj 81910.1001 Asbestos. (b) Definitions. Tor the porpow at this section, U) "Asbestos" Includes chiysotile. smosite. eroeldoUte. tremoUte. anthophylllte. and actinollte. (2) "Asbestos fibers" means asbestos fibers looser than S micrometers. (b) Permissible exposure to airborne concentrations 0/ asbestos /lben--(i) Standard effective July 7. 1972. Hu hour time-weighted average airborne concentrations ot asbestoa flben to which any employee may be exposed shell not exceed five flben, longer than S micrometers, per cubic centimeter of sir. as determined by the method preacHbed in paragraph <e> of this section. (2) Standard effective Jvlp 1, 1979. The 8-hour time-weighted average air* borne concentrations of asbestoa flben to which any employee may be exposed shall not exceed two flben. longer than 8 micrometers, per cubic centimeter of air. as determined by the method pre scribed In paragraph (e> of this section. 13) Ceiling concentration. No cm* ptoyee shall be exposed at any time to airborne ceneentrations of asbestoa flben in excess at 10 flben, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) of this section. <e> Methods of compliance--(1) fsgineering methods. (1) Engineering con trols. Engineering controls, such as, but not limited to. Isolation, enclosure, ex* haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (11) Local exhaust ventilation, (al Local exhaust ventilation and dust col lection systems shall be designed, con structed. installed, and maintained In accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSX Z9.2-1971. which is in corporated by reference herein. fb> See 11910.8 concerning the avail ability of ANSI Z9.2-1971, and the maintenance of a historic file in connec tion therewith. The address of the Amer ican National Standards Institute Is given m 11910.100. (hi) ParUaUar tools. AD hand-op erated and power-operated tools which may produce or release asbestos flben la excess of the exposure Unfits pre- Chapter XVIt--Occupational Safety and Health Admin. 11910.1001 scribed In paragraph (b) of this section, such as, but not limited to. saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems In accordance with subdivision (0) of this subparagraph. (3) Work practise*--(1) Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, eat floored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers In excess of the ex posure limits prescribed In paragraph (b) of this section, unless the usefulness of the product would be diminished thereby. (U> Particular products and opera tions. No asbestos cement mortar, coat ing. grout plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers In which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers In excess of the limits prescribed in paragraph (b) of this section. (fit) Spraying, demolition, or removal. Employees engaged In the spraying of asbestos, the removal, or demolition of pipes; structures, or equipment covered or Insulated with asbestos, and In the removal or demolition of asbestos In sulation or coverings shall be provided with respiratory equipment fat accord ance with paragraph (d> (2) <1111 of this section and with special clothing In aceordanee with paragraph <d) <3> of this section. (d) Personal protective equipment-- Cl) Compliance with the exposure limits prescribed by paragraph (b> of this sec tion may not be achieved by the use of respirators or shift rotation of em ployees, except: (1) During the time period necessary to install the engineering controls and to Institute the work practices required by paragraph <e) of this section: (ill In work situations In which the methods prescribed in paragraph <e> of this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of this section: or (111) m emergencies. <lv) Where both respirators and per sonnel rotation an allowed by subdivi sions (1). 01), or (111) of this subpaingraph. and both an practicable, person nel rotation shall be preferred and used. <21 Where a respirator Is permitted by subparagraph (1) of this paragraph, it shall be selected from among those ap proved by the Bureau of Mines. Depart ment of the Interior, or the National In stitute for Occupational Safety and Health. Department of Health. Educa tion. and Welfare, under the provisions of 30 CFR Part 11 <37 Fit. 6344. Mar. 25. 1972), and shall be used In accordance with subdivisions (1), (11). (Ill), and (iv) of this subparagraph. <1> JUr purifying respirators. A reusa ble or single use air purifying respirator. or a respirator described In subdivision (11) or (111) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in paragraph (b) of this section, when the railing or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. <11) Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described In subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre scribed in paragraph <b> of this section, when the celling or the 8-hour timeweighted avenge concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those Hmth (111) Type "C* supplted-air respirator), continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand. tuppUed-alr respirator shall be used to reduce the concentra tions of airborne asbestos fibers In the respirator below the exposure limits pre scribed In paragraph (b) of this section, when the celling or the 8-hour time- weighted avenge airborne concentra tions of asbestos fibers are reasonably expected to exceel ICO times those limits. (Iv) .Establishment of a respirator pro gram. (a) The employer shall establish a respirator program in accordance with the requirements of the American Na tional Standards Prnrtlr-* tn- tory protection. ANSI Z88.2-1989. which Is incorporated by reference herein. 511 ! **** RMC0800280000359 11910.1001 TWa 29--Labor (b) See 11910.6 cancemlnr the avadability of ANSI Z88.2-1969 and the mato- tenance of u> historic file In connection therewith. The address of the American National Standards Institute Is given In 11910J00. <c> no employee shall be assigned to tasks requiring the use of respirators If, based upon his most recent examination, an examining physician determines that the employee Till be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by bis use of a respirator. Such employee shall be rotated to another Job or given the opportunity to transfer to a different po sition whose duties he is able to perform with the same employer, in the same geo graphical area and with the same senior ity. status, and rate of pay he bad just prior to such transfer. If such a different position Is available. (3) Special clothing: Hu employes shall provide, and require the use of, spe cial clothing, such as coveralls or similar whale body clothing, bead coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4) Change rooms: (1) At any fixed place of employment exposed to airborne concentrations of asbestos fibers m ex cess of the exposure limits prescribed In paragraph (b) of this section, the em ployer shall provide change rooms for employees working regularly at the place (HI Clothes lockers: The employs Khali provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination if the employee's street clothes from hie work clothes. oil) Laundering: (a) Laundering of asbestos contaminated clothing shau be done ao as to prevent the release of air borne asbestos fibers In excess of the ex posure limits prescribed in paragraph <b> rf this section. <b> Any employer who gives asbestoacontamtnatcd clothing to another person for laundering shall Inform such person of the requirement to (a) of this subdi vision to effectively prevent the release of airborne asbestos fibers to excess of the exposure limits prescribed to para graph o of tins motion. <ci Contaminated dothta* ahaD be transported to sealed impermeable bags, >r other doted, impermeable containers. and labeled to accordance with para graph (g) of this section. <e> Method of measurement. AO de terminations of airborne concentrations of asbestos fibers shall be made by the membrane filter method at 400-450 x (magnification) (4 millimeter objective} with phase contrast illumination. <f) Monitoring--(1) Initial determi nations. Within 5 months of the publi cation of this section, every employer shall cause every place of employment where asbestos fibers are released to be monitored in such a way as to determine whether every employee's exposure to asbestos fibers is below the limits pre scribed In paragraph (b) of this sec tion. If the limits are exceeded, the em ployer shall Immediately undertake a compliance program in accordance with paragraph (e) of this section. (2) Pertonal monitoring--(1) sam ples shall be collected from within the breathing zone of the employees, on membrane filters of 0.8 micrometer po rosity mounted to an ooen-faea filter holder. Samples shall be taken for the determination of the 8-hour timeweighted average airborne concentra tions and of the celling concentrations of asbestos fibers. <U) Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b> of this section. (3) Environmental monitoring--(1) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected an a membrane filter of OS micrometer porosity mounted to an open-face filter holder. Samples shad be taken for the determination of the 8- hour time-weighted average airborne concentrations and of the ceding con centrations of ashestoa fibers. <il> Sampling frequency and pattenu. After the initial determinations required by subparagraph (I) of this paragraph, samples Shan be of such frequency and pattern as to represent with reasonable accuracy the levels at exposure of the *" miUT"-- Hi mm 4an m Chapter XVII--Occupational Safety and Health Admin. 11910.1001 employees. In no case shall sampling be at Intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para* graph <b) of this section. (4) Employee observation of monitor ing. Affected employees, or their rep resentatives. shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels. <l> Cau tion slans. (1) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be m excess of the exposure limits prescribed In paragraph (b) of this section. Signs shall be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps be fore entering the area marked by the signs. Signs shall be posted at ail ap proaches to areas containing excessive concentrations of airborne asbestos fibers. (ill Sign specifications. The warning signs required by subdivision (!) of this subparagraph shall conform to the re quirements of 20" x 14" vertical format signs specified In 11910.145(d)(4). and to this subdivision. The signs shall dis play the following legend in the lower panel, with letter sizes and styles of a visibility at least equal to that specified In this subdivision. Zeyead /fetation Wbestoe 1" Sana Ssitr. Ootble or Block. Dust Hazard_______ _____ %" Sana tail. Oothia or Block. Avoid Breathing Dust___ V4" OotMe. Wear Assigned Protective ^"Gothic, equipment. Do Mot Remain In Am V'Gothic. Unless Tour Work Re quires It. Breathing Asbestos Dust 14 point Gothic. May Be Hazardous To our Health. Spacing between lines shall be at least equal to the height of the upper of any two lines. (2) Caution labels--(]> Labeling. Cau tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent. coating, Under, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tions of asbestos fibers In excess of the exposure limits prescribed In paragraph (b) of this section will be released. (11) Label specifications. The caution labels required by subdivision (1) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible end legible. The label shall state: Caution Contains Asbestos Fibers Avoid cresting Dust Breathing Asbestos Dust May Cause Serious Bodily Barm (b) Housekeeping--ti> Cleaning. All external surfaces in any place of employ ment shall be maintained free of accu mulations of asbestos fibers If. with their dispersion, there would be an excessive concentration. (2) Waste disposal Asbestos waste, scrap, debris, bags, containers, equip ment, and asbestos-contaminated cloth ing. consigned for disposal, which may produce in any reasonably foreseeable use. handling, storage, processing, dis posal. or transportation airborne concen trations of asbestos fibers In excess of the exposure limits prescribed in paragraph (b) of this section shall be collected and disposed of In sealed Impermeable bags, or other closed. Impermeable containers. (1) Recordkeeping--(1) Exposure rec ords. Every employer shall maintain rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at least 3 years and shall be made avail able upon request to the Assistant Secre tary of Labor for Occupational Safety and Health, the Director of the National Institute for Occupational Safety and Health, and to authorized representa tives of either. (2) Employee cecess. Every employee and former employee shall have reason able access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the em ployee's own exposure to asbestos fibers. (3) Emplopee notification. Any em ployee found to have been exposed at any time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed in paragraph (b) of this section shall be notified In writing of the expo sure as soon as practicable but not later 513 i 1910.1001 TMg 29--labof than 5 days of the finding. Hie employee hall also be timely notified of the cor rective action being taken. <]) Medical examination*--(1) Gen* eroL The employer shall provide or make available at his cost, medical examine* tions relative to exposure to asbestos re quired by this paragraph. (3) Preplacement. The employer shall provide or make available to each of his employees, within SO calendar days fol lowing his first employment In an occupation exposed to rJrbome con* eentratlons of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram (posterior-anterior 14 x 17 inches), a history to elicit symptom atology of respiratory disease, and pulmonary function tests to Include forced vital capacity (FVC) and forced expiratory volume at 1 second (PWu). (3) Annual examination*. On or be fore January 31, 1973. and at least an nually thereafter, every employer shall provide, or make available, comprehen sive medical examinations to each of his employees engaged In occupations ex posed to airborne concentrations of as bestos fibers. Such annual examination shall Include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches), a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV, J. (4) Termination of employment. The employer shall provide, or make avail able. within 30 calendar days before or after the termination of employment of any employee engaged In an occupation exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall Include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 inches), a history to eilelt symptomatology of respiratory disease, and pulmonary function tests to Include foreed vital capacity (FVC) and forced expiratory volume at 1 second (VEVu). (5) Recent examinations. No medical examination is required of any em ployee. It adequate records show that the employee has been examined In ac cordance with this paragraph within the out leVMF period. (6) Medical record*--(1) jrgfate- sauce. Employers of employees examined pursuant to this paragraph shall causa to be maintained complete and accurate records of all such medical dons. Records than be retained by employers for at least 30 years. <il> Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, far inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of NIOSH. to authorised physi cians and medical consultants of either of them. and. upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the infor mation specifically required by this paragraph, and any other medical In formation related to occupational ex posure to asbestos fibers. 8 1910.1002 Coal tsr pilch toUiOcsi in terpretation of term. As used in 11910.1000 (TableZ-l).coal tar pitch volatiles tnclude the fused poly cyclic hydrocarbons which volatilise from the distillation residues of coal, petroleum, wood, and other organic mat ter (Sac. S(C). 84 Btst. 1600, 39 VSJO. 657) (39 FB 83503, June 37. 197S. Redesignated and amended at 40 FB 33073, May 38. 1175] 81910.1003 4-NkroUphenyL (a) Scope and application. (1) This section applies to any area in which 4-Nltrobiohenyl, Chemical Abstracts Service Registry Number 92933 is manu factured. processed, repackaged, re leased, handled, or stored, but shall not apply to trans-shipment In sealed con tainers. except for the labeling require ments under paragraphs (e) (3), (3). and (4) of this section. (3) This section shall not apply to solid or liquid mixtures containing leas than 0.1 percent by weight or volume of 4-NltroblpbenyL (b) Definition*. For the purposes of this section: (1) "Absolute filter*' Is one capable of retaining 99.97 percent of a mono disperse aerosol of 0.3 m particles. (3) "Authorized employee** means sa employee whose duties require him to be in the regulated area and who has been specifically assigned by the employer. (3) "Clean change room" means a room where employees put on clean clothing and/or protective equipment in an environment free of 4-NltroblphenyL Tbs clean change 'room shall be con tiguous to and have an entry from a shower room, when the shower room 314