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<UH i l cheiosi CC: L. C. Schaller-Emp. Rel.-Wilm. D. J. Baatty - Cent. Res. - Exp. ot E. I. du Pont de Nemours & Company R. W. Calhoun - Tex. Fib - beaford J. T. Cavanaugh-Pigments-Edge Moor . F. H. Dineen - Elchem - Wilmington Wilmington. Delaware imss E. B. Hall - Design R. B. Whitaker-Plastics-Victoria Pit H. Lewis-Explosives-Carney's Point ENGINEERING DEPARTMENT W. T. Muncaster - Elaschem - Wilming W. 5. Person-Orchem-Chambers Works W. H. Thompson - F & F - Parlin Plar. P. A. Palmer - ESD I. Zeise - Construction Refer to Serial Letter 4013 Dated November 8, 1971 December 20, 1971 TO: D. G. WINDSOR - CHAIRMAN - EMP. REL. - WILMINGTON FROM: D. M. ISIMINGER - STANDARDS STANDARDS SECTION - SAFETY & FIRE PROTECTION SUBCOMMITTEE S4T - MEASUREMENT AND CONTROL OF ASBESTOS DUST EXPOSURE Our request to the Engineering Standards Committee for approval of the above standard has brought the following comments: APPROVALS: H. B. Eaton, Elaschem; J. C. Breckenridge, Emp. Rel.; H. H. Kohl, F & F; C. W. Andrus, International; R. H. McConnell, Pigments; R. W. Beach, Purchasing NO REPLIES TO DATE: R. E. Robbins, Central Research; W. H. Davis, Elchem; C. S. Eller, BM tc ID; C. D. Brown, Construction; F. J. Martin, ESD; W. E. Neff, Film; K. W. Dahl, Plastics; R. H. Gruss, Remington Arms NOTED - NOT QUALIFIED TO COMMENT: R. F. Stewart, Design; J. P. Klimowicz, ERD MMENTS AND/OR SUGGESTIONS: REEDER. JR.. COMMENTS BY J. PAVLOSKI/R. FISHER - EXPLO. - REPAUNO WK5 IT MO. 1" - Will this concept be extended to all insulating materials and not limited to just asbestos? Many insulations contain no asbestos but are dusty and fibrous. Insulations containing silica, although less toxic, can cause silicosis and chronic lung disease. yCOMMENT NO. 2 - In paragraph 2.2, spray asbestos for insulation and fire_jproofing should be added as this is discharged directly from a hose to the atmosphere. Contractors sometimes do this work at Plant sites and adequate isolation of the area is advisable. A. PARMAN, COMMENTS BY J. A. FLATTMANN - I & B - GRASSELLI PLANT COMMENT"TiO. 3 - Will probably have to incorporate soma of this into Plant Safety Instruction. ~ 's` DUP I 153866 DU 062094 b.L. 4013 11/8/71 - *2 - December 20, 1971 v JOMMENT NO. 4 - If this comes under OSHA, we will also have to cover in 'arrangements with insulating contractors. . V. FLYNN, COMMENTS BY R. D. GOTWALS/W. S. PERSON - ORCHEM - CH. WKG. PMBB1T NO h - Does fcEe" 'TL7"n52T) meet "'proposed' Federal limits V USktd` 3MMENT NO. 6 - Exposure in a shop operation is somewhat different from irking on pipe lines in the field. Should we not mention the applicatio: <f\this Standard in field work as well? J. LAUR!N0. COMMENT BY J. J. LAURINO - PHOTO PRODUCTS - WILMINGTON ,3MKENT NO. 7 - Recommend that this standard not be issued until the new format indicating the part covered by OSHA is in use. $J. A- STGMAN, COMMENTS BY G. B. KIRKPARTICK - TEX. FIB. - OLD HICKORY ^COMMENT NO. 8 - 2.2b - Opening boxes of new insulation*' should read. ''Opening boxes and stocking bins from new boxes of insulation.". Old Hickory has made repeated sampling tests of this bin stocking operation and found them over TLV limits. Our safety rules are being changed (J\to include this operation where dust respirators will be worn. QMMENT NO. 9 - 3.1 - This may have to be rewritten to harmonize with comments above for 2.2b. 1r .QMMENT NO. 10 - 3.4.1 - This wetting down of insulation should carry a 'caution to refrain from wetting down hot lines where: a) Water could be flashed off to vapor and cause burns; b) Water could fracture pipe or weldments; c) Water could freeze out or slow down process flow in "on stream" lines. 3QMMENT NO. 11 - Dust respirators are to be worn anyway when removing nsulation.{2.2c). GpMMENT NO. 12 - 6.1.1 - Each area group of insulators at Old Hickory are ^ked to take at least one sample (not necessarily of 8 hrs. duration) on a different job each week. More samples are requested when there are indications of any change taking place or new types of materials are bein* tried. This type of sampling provides us with new data in some jobs and shows results of our efforts to improve dust control in other jobs. y J-.A-. SIOMAN. COMMENTS BY P, E. M. SOONS - TEX. FIB. - DORDRECHT - COMMENT NO". 13 - Change point 3.1.4 as follows: *vftlaze coating on block insulation reduces asbestos as a potential dust source." Available or not available is of minor importance here. `COMMENT NO. 14 - Add to 3.2.2: "Consideration also must be given to --'exposure of other personnel working in the area who are not directly involved". The same warning has been given in point 3*4.2. To our opinion, it applies here too. DUP 1153867 DU 062095 3.L. 4013 ll/a/71 - '3 December 20, 1971 WoMMENT NO. 1$ - Change 5.2 as follows: "Clothes must be kept free of /iust accumulation. Clothes contaminated with duat shall be varimm-ripansd /before taking them off. Avoid breathing asbestos dust when removing clothe Being more specific at this point is desirable. i '$Jk. SIGMAN, COMMENTS BY W. R. CLARK - TEX. FIB. - SEAFORD PLANT otRENT no. is...- y.i.2':"(kit. ---------------------------------------------- - 3.1.3 - Include vacuum or respiratory protection. Should f sample analyses so indicate. .COMMENT NO. 18 - 3.1.5 - Do not agree - Use of vacuum cleaner to clean up workbench.' ' Use of plastic bag okay, but question value of wetting bag unless done continually. This is not practical. yOMMENT NO. 19 - 3.2.1 - Recommend use of respirator with or without ''exhaust system. WmMENT NO. 20 - 3.2.3 - Assume portable vacuum cleaners are acceptable. tfflfrlENT NO. 21 - 3.3.1 - Why not eliminate use of asbestos cement? Use <Po<wer House cement, which contains no asbestos. 'COMMENT NO. 22 - 3.4.1 - Do not recommend wetting down. Do recommend Vacuum before' removal and for job cleanup. \0MMENT NO. 23 - 5.2 - Intent good - but how and to what extent? NT N_Q. 24 - Add - where dust problem exists. (5*3) NT NO. 25-6.1,1-Full #p shift not necessary - one hour is sufficient. A. SIGMAN, COMMENT BY B. R. BOLTON - TEX. FIB. - MARTINSVILLE PLANT COMMENT NO. 26 - fe.1.1 - Question need for sampling each operation for a /Tull 8-Rotor"shift monthly. Many operations are not continuous and 8-hour sampling is impractical. Also, sampling can show that TLV limits have never been exceeded in a particular operation. Some samples should be taken monthly others semi-annually or annually. J. A. SIGMAN, COMMENTS BY P. F. PHILYAW - TEX. FIB. - WAYNESBORO PLANT COMMENT NO. 27 - j.2.1 - Isbestos dust does not precipitate readily in cyclone collectors. A bag filter for asbestos dusts should be required. Comment NO. 28 - 5.3 - Adherence to this item will create problems in that a^ernate facilities must be provided which will result in lost time from thevjob. Unless there is a clear need for this item, it should be deleted. J./ A- SIGMAN. COMMENTS BY J. M. MARTIN - TEX. FIB. - CHATTANOOGA PLANT sqMMEN'lHftO'. 2$ - Not necessary to Isolate power cutting equipment in a separate work area if adequate exhaust system is provided. DUP 1153868 DU 062096 C.L. 4013 11/8/71 December 20, 1971 '/ {COMMENTi nNwO. j3v0 - Not necessary to wet innssuuxlactiioon wnhen emptying cyyccil<one if discharged into a plastic bag and sealed. " C-- O-- MM----ENT NO, 31 -- 4 P* refer twow wearn cm prvovtwevcwtaivtwe e9 quipme4n4vt when gsgtr; ipping insulation rather than wetting so that insulation can be reused. COMMENT NO. 32 - Question necessity of extensive daily clean-up; good raent should be exercised for frequency of clean-up. NT NO. 33 - Asbestos-cement should be avoided whenever possible. A. STGMAN COMMENT5 BY W. M. READING - TEX. FIB. - KINSTON PLANT(DIoAP?. COMMENT NO. jl - Tn general, we believe that the standard is basically &*)od but unrealistic. We would, at best, require a major modification or. our equipment and procedures to comply. SNT NO, 3$ - 3.1-2 - Insulation is lifted from boxes and cartons put rash dumpster. COMMENT NO. 36 - Neither vacuum or mask are believed to be necessary.(3-1.3 Would like tWoW know wherWe WtWo purcVhitamsWeV and whatfV14a w twyJppeW Wo4f insulation is available. We cannot accept Unibestos. (3.1.4) yJCOMMENT NO. 38 - 3*1.5 - We are not using a plastic bag or wetting the '--^scrap because"of slipping hazards and housekeeping problems that would be created. We frequently brush wests from table top into paper drum for disposal and do not allow accumulations to build up. COMMENT NO. 39 - 3.2.1 - Our saws are not isolated, but we have not beer, above the Tl" in our tests. Our exhaust system performs very well; however ` the dust is not wet down. Adjacent carpenter shop's outside exhaust system is tied into same system. Contents from cyclone drop into closed dumpster, ^ome fibers are lost in cyclone air exhaust outside of the building. _' 'COMMENT NO. 40 - 3.2.3 - The ledges, lights, inside of storage bins are ---^cleaned on a weekly schedule. Other parts of work area are cleaned daily or more frequently. . COMMENT NO. 41 - 3.2.4 - We are using Mine safety air sampling pUmp with 'the Millipore filter type Aerosol Cat. # MAWG037A0 pore size .8. The pump is battery powered. , '; COMMENT NO. 42 - 3.3.1 - We are using Eagle-Picker Super 66 which conforms 'Is' to Commercial Standard C.S. 117-49 issued by U.S.D.C. COMMENT NO. 43 - 3.3.2 - Would like to kaDwttoera tHsvtype of cement could qa purchased. \COMMENT NO. 44 - 3.4.1 - Impractical; would create a slipping hazard. Also impossible to protect electrical equipment. There is little liklihood that /this would be done unless a most elaborate and unusual precautionary proecdure was followed. DU 062097 DUP t153869 5.L. 4013 11/8/71 5 December 20, 1971 \ l_') COMMENT NO. 4$ - 3.4.2 - We are barricading the work area to keep people out.A certain amount of dust inevitably drifts outside of the roped off enclosure. Infrequent large removals have created considerable dust at .times. a/^OMMENT NO. 46 - 3.4.3 - We are putting our scrap insulation in boxes and cans but not wetting it down, nor do we believe it necessary to do so, MMENT NO. 47 - 4.1.1 - We do not believe this is necessary, but the ormation Ts pertinent. 3COMMENT NO. 48 - 5.2 - The men wear coveralls when working; however, noth is being done to keep them free of dust other than a brushing off from --- ^ tt*ime to time. The statement is ambiguous. NT NO. 49 - 5.3 - We have not insisted on this, Practical enforceis questionable. IMMENT NO, 50 - 6.1.1 - We are taking 2-eight-hour samples monthly as a and for historical file. )COMMENT NO. 51 - 6.1.3 - Samples are sent to Fell* Stein, Department of Occupational Health, University of Pittsburgh. _ A. STGMAN. COMMENTS BY A. PAETSCH - TEXTILE FIBERS - UENTROP WORKS /)MMENT NO. 52 - 2.3 - Standard S2t should be in conformity to the j latest threshold limit values (TLV's) or to the limits of German authorities (Staubforschungsinstitut). '/pOMMENT NO. 53 - 2.4 - Sample for asbestos fiber analysis may be obtained >y using an instrument as it is used by German authorities (Staubforschung institut), i.g. Konimeter. COMMENT NO. 54 - 3.1.5, 3.4.1 - Design of proposed work table is required. 3j3c0MMENT NO 55 - 3.1.5, 3.4.1 - Dust should be eliminated through vacuum __^/system. Wetting seems not to be successful because fine dust cannot be absorbed through water and will reduce the effect of the cyclone. COMMENT NO. 56 - 3.2.1, 3.4.1 - Working area should have a little vacuum in order to keep the adjointed areas free of dust. COMMENT NO. 57 - 3.2.1, 3.4.1 - Exhaust system should have provision of keeping'work place free of dust. 33~ftOMMENT NO. 58 - 3.2.1, 3.4.1 - Dust should not be wetted (see 3.1-5). ust collecting bag should be closed and thrown away. Vacuum system should be designed for using one-way-bags. DUP 1153870 DU 062098 5 .L. 4013 11/6/71 -6- December 20, 1971 OMMENT N0 59 - 3-3-2 - Not possible because the whole quantity cannot e used at any time. "XQifoflENT NO. 60 - 3.4.1 - Insulation will be used more than one time, Wet ift^ulation cannot be used. Insulation with finish is water-resistant, fr^MMENT NO. 61 - 3.4.2 - Which dimension should the area have? 'COMMENT NO. 62 - 3*4.3 - Area should be cleaned with vacuum svstem. Water should not be used. OMMENT NO. 63 - 3.4.5 (New) - If possible transportable work-table with acuum system should be used for working in the areas. fcofaffiNT NO. 64 - 5.3 - Gum or eating-tkbacco can be consumed in working ai^eas because breath-way will be kept wet. No smoking. No food. q^MMENT NO. 65 - 6.1.1 - Sampling should be carried out for a monthly shorter time. COMMITS MADE BY E. B. HALL - DESIGN - LOUVIERS V gOwMEWT NO. 66 - Suggest paragraph 3.1.3 be reworded as below in order to v--'effect parallel construction and improve clarity; 3.1.3 - Asbestos insulation blocks should be handled with care.. If dust cannot be removed by vacuum, respiratory protective equipment must be used. -B? w* H` "THOMPSON - F & F - PARLIN PLANT ^ _ ^COMMENT NO. 07 - This Is not necesaarllv good measurement on the Plant level in as much as this standard will probably form the basis for Plant Standard Practices or Standard Operating Procedures, which will take precedence from then on. Without a standard on this subject., local practices will vary from no protection to unnecessarily involved protection This looks like an excellent guide from the Plant standpoint. Thirteen Engineering Standards Committee members advise an estimated total of 150 uses for this standard as reference per year- k jk DUP 1153871 DU 062099