Document xdex8xR262a42mr36R79kpJjG

I'A j MC -Rtv; c 1 Shell Oil Company Shell Chemical Company Interoffice Memorandum KAY 4, 1984 FROM: TO: SUBJECT: P.J. SNYDER - SR. INDUSTRIAL HYGIENIST B.J. KERN MD - MEDICAL DIRECTOR ASBESTOS SURVEILLANCE The attached work product reflects a review of the DPMC Asbestos Program. As you know the recent Corporate H & S Audit suggested that additional employees be considered for inclusion in the annual medical program. While one would always like to have additional data, I believe we are now in a position to revisit the issue a^medical coverage. Since this document is rather lengthy you may find the recommendations on Page 7 of interest. Briefly, the key findings are: 1) Additional employees should have been included in the medical program due to past exposure. I estimate this number at 100. 2) Maintenance personnel other than insulators have brief exposures to asbestos which theoretically could exceed 0.1 F/cc. Medical surveillance should therefore be expanded. 3) A mechanism needs to be established to assure participation in the exam program (eg. are all insulators included?). 4) Recent contract changes (associated maintenance) reinforce the need to consider expanding medical coverage to crafts other than insulators. Lets discuss where we go from here. fid J Phil Snyder Attachment cc: R.R. Erickson J.B. Gross H.L. Lee EC8 Satellite PJS Chron PLAINTIFF'S EXHIBIT bov-oflMP PLAINTIFFS EXHIBIT 'JO?/#' &0 NOR-009701 DFMC ASBESTOS MEDICAL PROGRAM REVIEW i. introduction *In 1981 DPMC Management expanded the Asbestos Medical Surveillance Program to include employees who worked as pipefitters and boilermakers prior to 1972. This was in addition to the insulators who were previously in the program. An action item for Health and Safety at that time, was to identify crafts who were presently in excess of the criteria for medical surveillance. Generally this 'action level' is defined as 0.1 fibers/cc, 8 hr. TV.'A, occurring on a "reasonably predictable and repeated basis". This determination had been deferred until additional information could be collected on asbestos exposure. This report addresses this issue and presents recommendations for future medical surveillance. II. JOBS WITH POTENTIAL EXPOSURE TO ASBESTOS Historically asbestos exposure has been associated with insulation fabrication,- handling, demolition, cleanup, tear-out, re-insulating and from nearby workers engaged in such activities. During the time period 1962 - 1972 the number of crafts and employees potentially exposed was probably increased with the introduction of the "incidental maintenance clause". A rank ordering of past asbestos exposure jobs is provided as Table 1. Jobs with current exposure to asbestos are summarized in Table 2. This summary does not reflect any impact (if any) of the recent "associated maintenance" contract provision. NOR-009702 TABLE 1 RANK ORDERING OF HISTORICAL ASBESTOS EXPOSURE Work Group Insulators Pipefitters Carpenters Pre-1972 Exposure To Asbestos Reinsulation & removal Incidental insulation removal Cutting transite, lining welding enclosures with asbestos 1975 + Procedures in place Procedures in place Procedures in place Laborers Work area cleanup Contractor cleanup Pipefitters Boilermakers V.'elders Entering vessels, furnaces containing asbestos Minimized Welders Asbestos coqtaining fire blankets ^ Eliminated - CA Plant Operators 1969 - 1973 Asbestos used routinely Eliminated Epon I Operators Asbestos added to Epocryl 327 Eliminated Mechanics Performing brake jobs Procedures in place to minimize exposure Riggers Removing old exchangers and vessels which were insulated with asbestos Minimized Pipefitters, Machinist, and Boilermakers Cutting, installing and removing asbestos gaskets; sometimes with wire wheels Procedures in place to minimize exposure Warehouse Personnel Tinners Operators Handling asbestos gasket sheets, etc. Occasional covering insulation Procedures in place to minimize exposure Procedures required Occasional exposure to asbestos if present N0R-009703 CURRENT POTENTIAL ASBESTOS EXPOSURE 1) tQ.J -C to u CO J- a; QJ .X t- 0) 0 1 L-> Z JZ CO c c0 X2 <o ** cn~o m CU a) 0 5 _c CO r_ +J QJ CL +-> OJ J3 U 4J -r- QJ -- -X CL fO CO -r-- JO -C 3 0 S- QJ i- CO 3 OJ <o t/l S-- i/J i/I +J 0 CO a; > CO <-- <n "O 0 CL V-- tzu *-- E to qj u >> aj c JZ -r- i JZ C7> -<->>> c U 1------r- +J <*- QJ <+- cN 00 r-- 1-- -0 c +-> CO 3 jz to to u O +-> c -O +J U co CL C co QJ C QJ ^/1 O <C QJ OJ ^ to 1-- +J O 5 r-- C_J +-J +"> CO - f-- r- *r* *0os <0 CO tO >> 0 fO to oO *3 O z 10 to r- 3 t0 C0 "O QJ CO r-- OJ JZ 3 J3 JZ Q- +-> -a 4-> CO 0) C 3U c i- co OO O CO CO to to +-> S0 3z s- QJ +-> C QJ cl ra l/1 (O 0) ocv1II----CO r- (-- i- -X tcEOO +-> 3 U c OtOro- trQo +q->j tto to 31 c O 0).c CL Nl 4-> 4-J S- IS +j O 3O CO C 3 CO O c u QJ > O +> on "O r--to <0 +O-> z rC-- IOCL CA3 XOiJl/Z) f5>- +j C OE +J 4-> O3 1V/ to c ''aJ 0 r-- r-- -0 to CO CU *r- 4- > O CO QJ +-> r- L. 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CC 0 0 0 ez> z JC 4J 3 0 tn to s. QJ M C OJ JZ Q.4J L. L. cO O Oz JC +J 3 O tn <D U to u 0 4-> CO 1-- JZ 3 +-> to L. CO *-- Z c QJ 4-> C 1-- JZ CO +-> z 3 0 o: <n --<- o cn o 0 to 1 O r- o C CO 2 u QJ CURRENT POTENTIAL ASBESTOS EXPOSURE C UQ) 1C 3 </> S- t- o r<CODT> +rUOJ (/> cn o_ c co +r->- OS-) UJ l/> fO CD r-- C o *r- o T3 r- crO *S--to ro i=3-r-0 U- 3 3 zc o r-- E fr et in cn ZD i O tr> C rE cn r-- 1 Lf) -C 4-> ' * c s- c S- r oo <D 0) 0) E O Q. >> C cn a> c S- >- r" Ca^- or 0) o C 4-> OCO) 4-> +-> z o 3 r- O Q- 1 C +-> UJ 1 O 4-> O *r* => -C i. fO <D OJ J= E t*- a 4-> 3-0 0 +-> 0} LlJ S- c 4-> >>*- 3 S- O. cn o o r* (O 5 O flj*r u. z c to S *-> l/) Q. 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CO r" s- h" JC J3 +> a) jt Li_ <D 4P M c P> c 4-> < Q. 1- 3 p-- S- c &- cn r- O O ro O r- O N0R-009705 o5 III ASBESTOS IS CASES Ten Shell employees have recently been identified has having radiological findings compatible with a diagnosis of asbestosis (Table 3). Where possible each employee was interviewed to ascertain the 'known extent of his past asbestos exposures. Copies of these interviews without identifying information are provided (Attachment 1). Case 1 2 3 4 5 6 7 8 9 10 TABLE 3 ASBESTOSIS STUDY 12/83 Years Since First Possible Exposure -V Years Since Last Possible Exposure Job Assignment Comments 35 35 25 30 35 35 30? 35 37 38 10C 10C Not Determined 6 6 10C 10C 35 37 34 Insulator Pipefitter Engineer Insulator Exposure prior to Shell signif. Insulator Exposure prior to Shell signif. Pipefitter Boilermaker Pipefitter 1 Yr. probable exposure Weider Repairman/ Boilermaker NOR-009706 r. ( 6 In alt cases the interviewee described early work activities that could have had high exposure, albeit frequently of short duration. A review of the jobs worked by these individuals offers an opportunity to consider what pre-1972 crafts other than pipefitters, boilermakers and insulators should be identified for the asbestos examination program. IV. EXPOSURE LEVELS The available asbestos monitoring data reveals considerable variation in exposure levels depending on wind conditions, work location, removal procedures, etc. (Attachment II). While exposures infrequently exceed the current OSHA limit of 2 F/cc, 8 Hr. TWA, exposures associated with asbestos removal wet or dry occasionally may, exceed the medical surveillance criteria of 0.1 F/cc. In part, this is a function of the amount of time involved in insulation removal. To further understand the benefit of wetting insulation prior to removal, a controlled test was set up. The results, as shown in Table 4, indicate that water\helps' but does not guarantee acceptable exposure levels. The work''situation simulated was that of loosening the insulation with a wrench and removal by hand. Reportably pipefitters currently engage in such an activity l-4X/month for 5-15 minutes each time. This would be especially true for overtime pipefitting work. TABLE 4 MOCK ASBESTOS INSULATION REMOVAL JANUARY 1984 Air Concentration .94 F/cc 3.22 F/cc 1.33 F/cc .44 F/cc Sampling Time 11 Min. 11 Min. 10 Min. 10 Min. Work Activity Simulated Asbestos insulation inside bldg, was wet with v/ater, loosened with a wrench and removed by hand. Same as above but not wet prior to removal. * Asbestos insulation outside was wet with water, loosened with a wrench and removed by hand. Same as above but not wet prior to removal. NOR-009707 7 Considering this limited assessment and the data presented in Attachment II one may conclude that any insulation removal (wet or dry.) may result in a "peak" asbestos exposure hetween <.l - 10. F/cc. This upper range would be a probably worse case exposure for partially wet or dry insulation. If this exposure occurred for an estimated ten minutes then the 8 hr. TWA range would be: (.1 F/cc)(10 Min.) . , r/ . ('480 Min.) <*1 Y/zc = <.l upto (10 Min.)(5-10 F/cc) (480 Min.) .1 - .2 F/cc Although the actual exposure would be less if a respirator was worn, the criteria for medical surveillance would apply irrespective of respirator use. V RECOMMENDATIONS ^ 1. The following crafts should be added to the Asbestos Medical Program based on current exposure potential. Insulators (verify participation) * Maintenance personnel expected to or permitted to remove or cut asbestos more than 5 days per year. Pipefitters Tinners Carpenters Mechanics 2. The following employees should be added to the Asbestos Medical Program based on past exposure potential. Employees who worked prior to 1972 as: Pipefitters - Verify Boilermakers - Participation Carpenters Welders Epon I Operators (Attachment IV) CA Plant Operators (1969-1973) Laborers N0R-009708 (8 s 3. Per t'fie DPMC Asbestos Order, annual asbestos training should be provided to current Pipefitters Carpenters Tinners Insulators Mechanics Warehousemen 4. All future "presumptive cases of asbestosis" should be identified and interviewed in regard to past asbestos work. 5. To comply with the OSHA Asbestos Regulation the following jobs must be monitored every 6 months, (1 day survey) Tinners - Covering insulation Insulators - Asbestos removal work Carpenters - Cutting transite Maintenance needs tc^ assist Industrial Hygiene by coordinating air sampling and the fiela work. 6. Annually maintenance should review participation in the medical program for the jobs identified in #1 above. N0R-009709 o ATTACHMENT 1 9 i) esca Previous Employment: No application located. Date W 3/48 8/48 8/49 12/52 2/53 Occupation General Helper Pipefitter Helper No.2 Asbestos Helper No. 2 Insulator Helper Insulator No.2 Insulator No.l Department Utilities Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Narrative From Interview: 4/10/84 This employee has been assigned to the shop for the last 3 years. His work mostly involves fabrication of elbows, etc. The use of a vacuum on the saw has helped considerably over past practices (before 1970). There is only one shop insulator, the rest work in the field. According to this insulator the wetting of asbestos prior to removal doesn't always work. One can't wet the insulation all the way through and some dust is initially generated when the metal cover is removed. Before 1974 his exposures were sometimes significant, and more frequent (less asbestos in the field today). In vessels insulators would sometimes breathe through rags (when the dust was annoying). Today pipefitters will sometimes remove asbestos without following precautions; Relatively speaking they (the pipefitters) have the second highest exposure potential. Most older insulators can tell the difference between asbestos and non-asbestos insulation. However, operators don't know what areas contain asbestos and don't generally identify it for them. This employee stated that the craft foremen were pretty strict on following the work practices. Previous Employment: 9/43 - 2/43 Jess McNeil - Tractor Operator 1/44 - 7/46 US Marines - Telephone installer 7/46 - 7/48 Westinghouse Electric - Installer Date im 8/48 2/49 2/53 2/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Interview: This employee declined to discuss asbestos. NOR-009710 L 10 3) No previous employment reported. Date ~SJV5 6/50 8/51 8/52 6/53 1/54 1/56 2/58 3/59 3/60 6/61 6/64 7/65 7/68 7/70 9/73 4/77 Occupation Department Location Jr. Lab Assistant Mfg. Research Lab Houston Refinery Lab Assistant Mfg. Research Lab Houston Refinery Technician Lab Mfg. Research Lab Houston Refinery Military Reserve (8/10/52 - 8/25/52) Military Reserve (6/7/53 - 6/23/83) Military Leave Released to return to school. Technologist Technologist -. Technologist Technologist Engineer Engineer Sr. Engineer Group Leader Process Manager v V Process Manager ^ 4) ess Previous Employment: "Insulator. 24 years experience in Chemical Plant". (Diamond Shamrock, Painesville Works) Navy: Radioman Date 2/77-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative From Interview: 4/10/84 Worked at Diamond Shamrock (Ohio) as an insulator between 1953 and 1976. Even in 1974-1976 they had no required precautionary procedures as does Shell. Insulators were only told about the hazard of asbestos not required to do anything different. This individual indicated that he always had used a "paper type" (Martindale) respirator even at Diamond. Much of his work at Diamond involved cutting and fabricating insulation outside. This employees assignments today are predominately at Resins. Some areas have asbestos, some don't. He encounters asbestos occasionally as during dismantlements and shutdowns. This employee stated that he was glad that he has had no effects from his past exposure (evidently he has not experienced overt symptoms from his asbestosis). He currently smokes less than 1 pack a day. NOR-009711 11 Regarding current work practices he stated that the "wet procedure" is pretty effective in reducing dust levels. Residual asbestos on piping is hosed off. This employee appeared to be reasonably knowledgeable of asbestos' hazards and very aware of the hazard associated with contaminating his work clothes. He did indicate, however, that for small jobs coveralls would not be used. He is careful that his family doesn't handle his work clothing. This employee further indicated that the management of contaminated clothing isn't stressed by Shell. He occasionally brings contaminated garments to the Tool Room in unlabeled bags. He doesn't use paper coveralls because they lack pockets. Regarding other crafts, he indicated that pipefitters don't have respect for asbestos. He occasionally has to get fitters out of an area where insulation is being removed. Overall, this insulator stated that Shell had a pretty good safety program, with one exception. At Diamond Shamrock walking through roped off areas and not posting areas when work was going on overhead wasn't tolerated by management. 5) gSZZI 'V Previous Employment: 4/1/48 - 1976 Insulator Group Leader at Diamond Shamrock. Date 2/77-83 Occupation Insulator No. 1 Department Maint. Engr. Location DPMC Narrative From Interview: 4/10/84 He has worked at Diamond Shamrock since 1948. Also wore respirators about as often as he does now at Shell. However, he runs into less asbestos at DPMC since it is slowly being replaced. He changes his clothing in the Carpenter Shop (not the changehouse), but he does shower before leaving work. Contaminated clothing is given to the Tool Room for cleaning in labeled bags. Regarding pipefitters, he suggested that their asbestos exposure is about 5 minutes per day on days when they encounter it. In some occasions this may be extended especially on overtime work. By personal observation pipefitters don't always use respirators. Sometimes it is difficult to tell whether or not insulation is asbestos especially if the covering metal is new. This probably presents a greater problem to new, younger pipefitters. NOR-009712 C 12 6) SZ Previous Employment: 9/47-6/48 General Helper, C.F. Braun, LaPorte.Tx. 8/46-9/47 Truck Driver, Dayton, TX. Date STW 7/48 12/48 2/53 9/53 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Pipefitter Helper No.2 Pipefitter No.l Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field (IC) Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 Since 1948 this employee has worked as a pipefitter. In reference to early asbestos exposure, he described working along side insulators and personally removing asbestos as necessary. On occasion the clothes he wore home were "white" with insulation. This employee noticeably becomes, short of breath upon exertion. He described his present difficulty in climbing pipe racks. He now has to stop to catch his breath before proceeding with the work. This employee indicated that he has never smoked. Reportably the asbestos exposure today (in comparison to the past) is like "day and night". This improvement is mostly attributable to the current practices followed by insulators, (which began about 8 yrs. ago). Current asbestos jobs include: 1) scraping (sometimes sawing) off gaskets and 2) removing insulation (5-10 min. jobs). Sometimes v/ater is used to remove asbestos, sometimes not - depending on the individual.. A pipefitter may remove asbestos 2X/week. As this employee has worked OP-II since 1969, the above description of current practices would only apply to the Olefins OP-II area. This employee ranked pipefitters as having the second highest exposure potential (after insulators). Respectively #3 and #4 were boilermakers and machinists. Prior to Shell this individual worked for C.F. Braun as a brickmason helper. No asbestos exposure was attributed to this job. NOR-009713 o 13 Previous Employment: 46-47 Self employed mechanic. 1/51-7/52 Millwright at Portland Cement Millwright at Ethyl Corp. Millwright at Rheem Manufacturing Date 9/5? 10/52 10/52 1/53 1/53 4/53 9/53 5/54 6/60 8/63 8/66 12/66 7/67 6/68 10/68 Occupation General Helper Loader General Helper Truck Driver No.2 General Helper Loader Boilermaker Helper n Boilermaker Helper n Boilermaker #2 General Helper Operator #2 Loader . v .*! Operator . ^ Loader Boilermaker Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field Shipping Eng. Field Eng. Field Eng. Field Eng. Field P Operations Shipping Shipping Shipping Maint.Eng. Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 As a General Helper, this employee primarily assisted the boilermakers, pipefitters and machinists. His contact with asbestos during this time was related primarily to working in areas where asbestos was being removed. At times it would look like "snow falling from overhead". Boilermakers frequently knocked off asbestos insulation to get to the heads of exchangers or boilers. This employee recalled having his clothes covered by asbestos on occasions. Respirators were not available until early 70's, however, goggles were the only way to keep it out of eyes and sometimes a rag would be tied around the nose and mouth if conditions were intolerable. When asked the difference between conditions of earlier years 50's & 60's and today, this employee said "There is no comparison between how it was then and now". He was referring to the work practices which require it to be wet, bagged, with coveralls and respiratory protection. The frequency of boilermakers having to remove the insulation has also been dramatically reduced because there "just isn't as much asbestos around". Occasions may still occur but they are infrequent compared to earlier years. This employee believes the pipefitters'and boilermakers to be second only to the insulators in asbestos exposure. The areas this employee worked were field assignments all over the Chemical Plant. He was a Plannable Boilermaker for several years. Since 1983 he has been assigned to E Maintenance. Regarding the time spent as a Loader in Shipping Dept, he commented on exposure to BPA and resins dusts in the Warehouse. NOR-009714 > 14 8) Previous Employment: 7/40-7/42 Westinghouse Electric - Motor Repairman 7/42-11/45 U.S. Navy-Radioman 1/46-3/48 The Texas Co.-Painter Date w 5/48 8/48 9/52 10/52 2/56 6/56 11/76 Occupation General Helper Pipefitter Helper No.2 Pipefitter Helper No.l Instrument Man Help.No.2 Instrument Man Help.No.l Instrument Man No.2 Instrument Man No.l ' Instrument Man/Foreman Department Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Location Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Houston Refinery Interview: Not Conducted (Retired) 9) ^gsgaasasgrsag Previous Employment: -\ 8/46-7/48 The-Texas Co. - Tatik Truck Operator 4/46-8/46 H.H. Hardy - Guniter* *Reason for leaving was "doctor advised". Date im 9/48 9/48 9/48 2/53 5/68 Occupation General Helper Loader General Helper Welder Helper Welder No.l Wel-der/Craft Foreman Department Eng. Field Shipping Eng. Field Eng. Field Eng. Field (IC) Eng. Field Location Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Shell Chemical Narrative From Interview 4/9/84 This employee clearly remembered working with an insulator in the removal of asbestos at G Plant during the first week of employment. During this initial 3 month assignment as a general helper and loader, he had "a few days" of definite exposure to asbestos. His assignment as a welder since 1948 was associated with asbestos exposure upto the time period when its hazards were better managed (early 701s). Welder field assignments did not actually involve insulation removal. However, after insulation was removed he would have to work in areas which were contaminated with the asbestos. On at least some occasions the loose asbestos would be on scaffolding (some jobs required him to work lying down on contaminated surfaces'). This welders work historically has been associated with furnaces and reactors. This employee noted welders past use of asbestos fire blankets and gloves. Before asbestos controls were put in place asbestos contaminated piping v;as brought into the shop. As in the field the loose fibers after the insulation was removed resulted in some potential exposure. This employee has predominately worked in the shop since 1974. Prior to Shell he worked for H.H. Hardy as a guniter and could not recall any exposure to asbestos. N0R-009715 o 15 io) Previous Employment: 12/43-4/44 Worked on fathers farm. 9/41-1/43 Dairy Work 9/43-12/43 North American, Dallas - Plating and Buffing HSs been at Sulfur Springs with father since 12/43. Date 4/44 8/45 1/46 8/46 6/48 6/49 1/72 2/74 2/77 11/80 Occupation General Helper Repairman Helper General Helper Boilermaker Helper Boilermaker No.2 Boilermaker N'o.l Craft Foreman & BM #1 Zone Foreman Foreman DPC (Zone A) Maintenance Foreman Department Gas Car Eng. Field Eng. Field Eng. Field Eng. Field Eng. Field Maint. Eng. Maint. Eng. Int.S Solv. Location Houston Refinery Houston Refinery Chemical Chemical Chemical Chemical Chemical Chemical Chemical Chemical Narrative From Interview 4^18/84- * - This employee is currently a multi-craft foreman in A Maintenance. He worked as a boilermaker in the Chemical Plant from 1946-1974. One significant recollection this employee had about asbestos was how craftsmen would often use air hoses to blow the insulation away from their immediate work areas. He also recalled using a hammer to remove asbestos insulation around the bolts on exchanger heads. The cleanup of stripped insulation was poor. "Unless it was a tripping hazard, it was left in the area". When asked which crafts were probably exposed the most frequently he named pipefitters and boilermakers as second and third to the insulators. Today he feels the usage of proper protective controls is about 80% by all of the crafts. The "associated maintenance" which is now in effect he feels will involve additional crafts in insulation contact ie. instrument men, electricians, machinists. This employee was not aware that an annual training requirement exists for asbestos at DPMC. He feels that reinforcement of training is very important and suggested that our department design a presentation for all of the crafts which includes demonstrating how indestructable asbestos is. Regarding protective clothing for asbestos he felt that paper coveralls should be specified for asbestos work because they can be disposed of. He commented that if craftsmen wear cloth coveralls for asbestos that they are likely to keep them on for the duration of the day. N0R-009716 c( 16 Additional Interview: 4/19/84 (Not An Asbestosis Case) Tin's employee is currently an hourly maintenance foreman at Aromatics. Since 1976 he.has worked as a pipefitter in Maintenance East. The frequency of contact an individual pipefitter might be involved in an asbestos related job this employee estimated as once or twice a month for 15-20 minutes. The practice used today is to have the insulation checked to determine if it is asbestos before performing the work. If this cannot be done it is assumed to be asbestos. Pipefitters may not always wear coveralls, however, most will wear a . respirator and sometimes wet the insulation and cover the ends to keep -, it from shaking out while performing their work. This employee did recall an occasion where he found out after the job that the insulation was asbestos and no protective clothing was worn. For most of the jobs he plans now he tries to have the insulation removed in advance to avoid having other crafts exposed to asbestos during insulation removal. (This was done recently in preparation for the Aromatics* Shutdown). He personally dos not beat off insulation with tools but will use a saw or cut it to minimize dust because he has to clean up his own mess. This employee is not presently in any of the medical programs at DPMC. He feels that pipefitters and boilermakers with service prior to 1975 should be included in an asbestos medical program and that perhaps a random number of various craftsmen could be included post 1975 Asbestos Medical Program. He does not-think the "associated maintenance concept" will be affected any differently in regard to asbestos exposure. He also mentioned that craftsmen working in the Utilities may have more frequent contact with asbestos. When asked the order he would rank different crafts exposed to asbestos he named insulators #1, laborers #2, carpenters #3 and all of the other crafts #4. Overall the craftsmen are pretty knowledgeable about asbestos. It is frequently discussed in Safety Meetings. Practices probably vary depending on individuals and foreman but generally precautions are followed, to his knowledge. N0R-009717 Cleanup Date 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study 11/72 11/72 11/72 7/78 7/78 7/78 7/78 7/78 7/78 Demolition 1972 DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study DOSH Study 0G ATTACHMENT II . _ ' HISTORICAL ASBESTOS BREATHING ZONE EXPOSURE DATA 17 F/cc 4.5 1.5 2.7 1.0 1.6 .3 1.43 1.36 4.51.6 .15 .32 .35 0.01 0.04 0.01 0.01 0.02 0.04 Sampling Time 2 Min. 7 5 6 17 35 22 1SV 31 22 16 30 190 190 180 190 120 no Activity Type Field cleanup Unibestos Field cleanup Unibestos Field cleanup Unibestos - Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Field cleanup Magnesium Cleanup Thermobestos Cleanup Thermobestos Instal1ing Thermobestos insulation (EA) Christensen Laborers Cleaning up asbestos insulation during demolition of water softeners (Wet) 2.55 2.62 .16 .93 .54 1.64 .85 1.01 .51 1.77 .26 1.76 1.02 1.63 15 15 15 15 9 9 15 15 15 15 9 9 11 11 Removing from charge pump Removing from transfer line Removing from exchangers II II II n 11 11 u 11 Unibestos Firetard co . ing and block insulation II II II n u u M 11 NOR-OQ9713 c C 18 Date ~ F/cc Sampling Time Demolition (cont'd) Christenson Co. - Utilities/Water Treaters 7/78 .02 120 7/78 7/78 7/78 7/78 7/78 .01 190 .04 190 .01 180 .01 190 .04 110 ' . Activity Cleanup of wet insulaItIion II II II It Type Carpenter Const. Insulators - 1978 Demolition of Water Softeners 8/78 8/78 8/78 8/78 0.17 0.09 0.73 0.54 195 Min. 165 200 . 150s- Stripping insulation from water softeners (Insulation wet) MIMI Pipefitters At Sulfur Recovery Unit/EP 8/78 8/78 8/78 9/78 9/78 8/78 10/78 .03 130 .20 120 .14 125 .39 125 .14 120 .25 123 .18 132 Removal and disposal of asbestos insul ation off piping in wet condition B & R Insulators at DU 1 & 3 3/80 3/80 3/80 .02 115 .01 150 .01 180 Stripping insulation from column. II B & R Insulators during DU- 2 Shutdown 4/83 4/83 4/83 0.15 0.10 0.12 445 435 451 B & R Insulators at Thermal Cracking 5/83 5/83 5/83 5/83 0.38 0.21 0.37 0.65 420 420 420 420 ' Stripping insulation off piping - wet. Stripping insulation off piping - wet. NOR-009719 C Date Replacement 1972 DOSH . Study (File 752) Fabrication 1972 DOSH Study 11/72 11/72 4/79 F/cc .45 1.5 .72 1.24 1.34 1.98 .20 .45 .36 .43 .13 .13 .16 .37 1.28 1.1 Sampling Time 19 19 37 37 15 15 40 30 10 90 120 85 2*v 30 19 19 O Activity.'- Wiring used insulation in place. 19 Type Unibestos Cut fabrication of insulation in Shop. Saw has exhaust ventilation - Thermobest (6% asbesto Cutting and handling outside. Cutting outside at Solvents & Treating. Thermobest Transite NOR-009720 m. \ ' OC Sliell-Oil Company a Shell Chemical Company InU-rolllcc J/.ciHotnndum fEBRUARY 13, 1981 PRjvATr. Arm confidential FROM: SUPERINTENDENT S & IH TO: COMPLEX MANAGEMENT TEAM SUBJECT: REVISED ASBESTOS MEDICAL SURVCILLANCE PROGRAM 76 & -- " J'W Corporate Medical issued a revised asbestos medical surveillance policy late last year which included in addition to "insulators" who are the , . only craft currently included in the Shell asbestos medical surveillance program, other employees who may also be exposed to asbestos as a result of their v.orlc activity. A review was made with both Maintenance - North and South of work activities prior to and following 1972. The year 1972 was used since there was a step change made in our handling of asbestos containing materials at that time. Based on this review, the following recommendations are offered: 1. Include in the asbestos medical surveillance program all pipefitters and boilermakers still with Shell who were working in [these crafts prior to 1972. It is estimated that we have about 94 employees (bh South and 39 North) tliat meet this criteria. 2. Initiate an expanded asbestos monitoring program to es tablish more firmly whether or not we are meeting the permitted exposure limits for employees working thes`e crafts today. The'limited data we have suggests that we are within the permissible exposure levels. Conse quently, no action is proposed for the employees who entered these crafts subsequent to 1972 until the addi tional monitoring has been completed. Inclusion of the craftsmen neetir.g the 1972 criteria in the asbestos medical surveillance program should be initiated early this year. The following plan is proposed for accomplishing this objective: 1. Identify the employees in the two crafts. 2. Advise the Workmen's Committee Chairmen and the H & S Conniittees of the revised policy. 3. Meet with the affected personnel and advise them of the new program. NOR-009721 n. - 'i m'I,.")'I,in1 oc CUT oc 2 4. Medical set time for examination, if required, and if not, a time for consultive session. 5. Issue bulletin on revised program with a follow up hazardous material bulletin outlining synergism of asbestos and smoking, etc. Be glad to discuss. R. v. i-ruuger RPF:cfh ) D. 0. Chrismer- ` J. G. Massey F. G. Reitz ' P. J. SnyderMedical Dept. ) N0R-009722 SHELL ASBESTOS MEDICAL SURVEILLANCE PROGRAM Pertinent Background Facts on Asbestos - Asbestos is a human carcinogen. Inhalation may cause lung cancer, mesothelioma, and other diseases such as asbestosis and pleural lesions. - Generally, the incidence of cancer and asbestosis among occupationally exposed persons increases with increasing intensity of exposure; the inhalation of high concentrations for short durations may be as * harmful as prolonged exposure to low concentrations. - - From all available evidence, the period between first exposure to asbestos and death from lung cancer appears to be related to intensity of exposure. A latency period approximating fifteen years is probably the minimum for asbestos-related lung cancer. V - Tobacco smoking increases the incidence of lung cancer and complicates asbestosis among asbestos workers. Regulatory Background - Permissible exposure limits to airborne'concentrations of asbestos fibers are defined by OSHA standards (29 CFR 1910.1001) as follows: a) Permissible exposure level -- "The 8 hour time-weighted average airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers, per cubic centimeter of air..." b) Ceiling concentration -- "No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air..." - Per OSHA Program Directive #300-16 dated October 11, 1978, titled, "Minimum Airborne Fiber Concentration For Initiating and Continuing Asbestos Medical Examinations", the term "...exposed to airborne concentrations of asbestos fibers;.." is administratively interpreted to mean "__ exposed to a minimum of 0.1 asbestos fibers longer than 5 micrometers per cubic centimeter of air..." on a time weighted average basis. Shell Concerns - Surveys now indicate that in addition to "insulators" who are currently included in our asbestos medical surveillance program, other employees such as pipefitters, riggers, etc. may also be exposed to asbestos as a result of their work activity. Our current medical surveillance program does not satisfactorily address the question of past exposure to asbestos. NOR-009723 o o r~'\ i - Employee training programs for asbestos have not sufficiently emphasized the known synergism between asbestos exposure and smoking. Objective Revise existing asbestos medical surveillance policy in order to correct any deficiencies and fully address the concerns described above. Policy - Employees whose present job assignment results in exposures to asbestos of 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall be included in Shell's annual asbestos medical surveillance program. - Employees, who can be identified as having had job assignments in the past, in which exposures can be determined as probably exceeding 0.1 fibers, longer than 5 micrometers, per cubic centimeter (TWA) or . greater (regardless of respirator usage), on a reasonably predictable and repeated basis,* shall also be included in an annual asbestos medical surveillance program. - Available exposure data indicate that exposures during "ripout" or removal of asbestos-containing insulation may exceed 0.1 fibers per cubic centimeter. Accordingly, all employees, regardless of job title, whose work assignments now or- in the past, would involve "ripout" or removal of asbestos-containing insulation, on a reasonably predictable and repeated basis,* are to be included in an annual asbestos medical surveillance program. - Employees who have been in an asbestos medical surveillance program prior to employment with Shell shall be included in Shell's annual program. - Once an employee has been included in an asbestos medical surveillance program, the surveillance should be continued throughout the term of his or her Shell employment. Upon leaving Shell, each employee who has been included in an asbestos medical surveillance program shall be administered according to the Shell pre-separation counseling or extended medical surveillance program policy (post-retirement physical examinations), whichever is appropriate.- * The phrase "reasonably predictable and repeated basis" is currently interpreted for present job assignments, to mean at least eight hours of exposure per calendar quarter. For exposures that have occurred in past job assignments, "repeated" shall mean at least two calendar quarters. It should be recognized that these exposure criteria represent an administrative judgment, since minimal exoosure levels required to cause disease are not known with certainty at this time. This administrative judgment may be revised in the future, with the concurrence of Corporate Medical, Toxicology, Safety and Industrial Hygiene and the affected functional management. N O R -009724 oo oc 3 Implementation: Suggested Action Plan/Guidelines - Evaluate exposures arid identify employees whose job assignments, now or in the past, result in exposure to asbestos as defined in the Policy, and include them in the annual asbestos medical surveillance program. - Due to the varied nature of potential exposure throughout Shell, . there may be specific employee concerns that will require the prudent, balanced judgements of both functional management and the Head Office Corporate Medical and Safety and Industrial Hygiene Department. Full ~ consultation, prior to arriving at a decision, is encouraged in these cases. - For the above identified employees, provide improved training and information to emphasize: .a^Synergism of asbestos and smoking. b) Need for participation in medical examination programs. * - Review current operating procedures for reducing or eliminating physical contact between asbestos fibers and employees. N0R-009725 ATTACHMENT IV PDU - 1956-1976 - Foon I 1968-1976 w 20 AS8EST/04 5-2-84 NOR-009726