Document ykx6qE6armrRg9eMM79OEkqvn

3 chaj:\ ja : V SV. . 5.5E11 E l.`i TO: FROM: SUBJECT: W. Krebs, Ph.D. (Chairman) H. Lick L. Gendemauk, Ph.D. T. Massaro General Motors Corporation Ford Motor Company Chrysler Corporation American Motors Corporatioi International Harvester R. A. Stolberg Ad Hoc Group o; eting November 14, 1974 The Chairman of this new Ad Hoc Group ha6 requested a meeting be scheduled for: Thursday, November 14, 1974 9:00 a.m. - Room 729 MVMA Detroit Offices The preliminary agenda will be to review the present OSHA Standard 1910.93a Asbestos (39 FR 23543 - June 27, 1974). OSHA has indicated their intention to offer amendments to this standard to be promulgated before the end of this year. The following materials are attached for background infor mation on this matter: - MVMA Action Bulletin S74-590 * - ASTM E-34 Mineralogical Definitions and Ballot - ASTM E-34 Draft Recommendations for an Asbestos Standard - AIA/NA Letter and recommendations to OSHA for revision of asbestos standard - ANSI Draft standard (5/2/74) "Fundamentals Governing the Design and Operation of Local Exhaust Systems for the Control of Asbestos - Containing Dusts". Please review these materials before the meeting and bring them with you for discussion purposes. RAS/bt 4I# Attachments (5) 8005 12*9 PRODUCED BY FORD SCF-ALLF-05160 MOTOR VtHICK MANUFACTURERS ASSOCIATION OF THE UNITED STATES. INC. >20 NEW CENTER BUILOING DETROIT. MICHIGAN 48202 872-4311 AREA II) ROY 0. CHAPIN. JR, Chairman FRANKLIN M. KREML, President end Chmt Ciecvtitre Otlicar RUSSELL E. MteCLEERY. Vice President October 16, 1974 TO: Occupational Safety and Health Committee (OSHC) FROMi R. A. Stolberg SUBJECT: OSHA revisions of the Asbestos Standard, 29 CFR 1910.93a Mr. Harry Gilbert, Project Officer, Office of Standards, OSHA, indicated at a Washington, 0. C. meeting with the Asbestos Information Asssociation (AIA) that amendments to the standard will be proposed on or about November 1 and a new standard probably would become effective in June, 1975. See Attachment I for a report of this meeting. Recently I received an inquiry from Mr. Robert H. Mereness, executive director of AIA, regarding whether or not MVMA had submitted comments regarding new amendments. He indicated that OSHA had contacted their association for recommendations and these were submitted July 15. I requested a copy of the AIA recommendations to OSHA and he agreed to provide this material. Mr. Mereness felt that a proposed standard would be promulgated before the end of this year by OSHA. See Attachment II for background concerning the AIA Committee membership and recommendations. Mr. Mereness represents a friction materials manufacturer and questioned if some of MVMA's member companies did not also have similar operations. He was concerned about the Union's recommendations for a zero asbestos fiber limit and the findings of a study reported by Dr. Selikoff's colleagues, "Asbestos Exposure During Brake Lining Maintenance and Repair" Arthur N. Rohl, PhD. et al presented as paper number 223 at the 1974 AIHA conference. I asked Mr. Mereness if OSHA was familiar with the activity . of ASTM Committee E-34, Task Group on Naturally Occurring Inorganic fibers (Action S74-564). Although he was aware of this committee, he indicated their progress was primarily in the area of defining asbestos and didn't consider their ir-u* to OSHA significant. 8005 1250 PRODUCED BY FORD OSHC 2 October 16, 1974 Action Requested Please review the attached information as this subject will appear as an agenda item for discussion at the next OSHC meeting scheduled October 25, 1974. #* RAS/bt Attachments (2) 8005 1251 PRODUCED BY FORD *38 including the dale. lime. location. results obtained person making tests. ;in<l calibration date of equipment shall be maintained at the job sile II conecntralions roach 25 parts of carbon monoxide per million parts of air <0.0025 percent), teals should be made mure frequently Concentrations should mil exceed :<S parts per million 10.0035 percent) at any time at employee breathing zones. When concentrations do exceed this level, employees shall leave the area and ad* ditiohal natural or mechanical ventilation shall be provided. No persons sltall be permitted to he within the area being Seated by the salamanders except when tending them, when testing the atmosphere, or in emergencies. Throughout the discussion of the proposed standards Robert M. Fared, safely director, International Union of Operating Engineers. Countryside. 111., said that this stan dard should not be promulgated because salamanders are only permissible under interim orders in three states and the District of Columbia and that only a few are still being manufactured. "We are virtually making a standard for a piece of equipment that basically does not exist,," he said. Farrell alluded to the difficulty in getting covers for salamanders due to the fact that most salamanders now in use are fabricated by the construction companies using them and the present materials shortages could deter compliance. "It's an unenforceable code." he said. Asbestos OSHA WILL PROPOSE AMENDMENTS TO RULES FOR ASBESTOS IN NOVEMBER, AIA IS TOLD Amendments to the standard for occupational exposure to asbestos. 29 CFR 1910.93a will be proposed on or about November 1, according to Harry Gilbert, project oflicer. Of fice of Standards, Occupational Safety and Health Ad ministration. Addressing the Asbestos Information Association in Washington. D.C., on September I M2. Gilbert said the new standard probably will become effective in June, 1975. Citing recommendations made by the AIA (Current Report. August 22, p. 3271, he noted not all may be adopted bv OSHA. but all will he given careful consideration Deleted from the present standard will be those requirements that "are an onerous burden on employers with no benefit to health und safety, to an effort to aid in voluntary compliance since there are limitations on the number of industrial hygicntists and compliance officers available to make in spections." he said. Ur Daniel Boyd, director. OSHA Office of Standards, said mure efficient standards-making processes are needed to avoid duplication of efforts ff a standard is developed by a consensus organization it undergoes an extensive process, and I ve gut to take it through C<bt." he said, adding the American National Standards Institute has been named as an interpreting agency tor all organizations dealing with standards development. Bovil said ANSI has been "very responsive." to the needs of OSII A He referred also to a new task torre in the Standards tillice. headed hy Dr Don laissilcr tsec relnted story this issue which will set priorities lor standards development Rr>-d said once these prinrities are established, the standard* .-tting mechanism will be engaged in the ntnst efficient ,,., possible. ANSI will Iijvi- a lull-time Washingti.,,. 1) ('. director of -.del) and health who will deal closely woo OSIIA ANSI will not write Ihe si.mtl.oiK hoi will eoordinale wilh the National Fire Prnlcriun Association iNFI'At. the American ('oiili-roner o! ttnvcrnincnt.il Industrial llygiensls < AtXSIH ATTACH#U'lZ 9/19 /74 OCCUPATIONAL SAFETV ft HEALTH REPORTER and the American Society lor Testing ami Materials t ASTM I. and oilier consensus groups, where Input Is needed. Bnvd noted also the need fur better coordination with other Government agencies. Reorpeniraiion Assilanl Labor Secretary John II. Stcndcr said OSHA recently completed a major reorganization of the Office of Standards Development, increasing (he staff, and realigning it along task force lines, "This will permit us to anticipate problems like asbestus. pesticides, and vinyl chloride before they are upon us." he said. Stcnder noted also the joint OSHA-Naliona) Institute for Occupational Safety and Health standards completion project that will produce complete health standards for uver 400 toxic substances. Union Chargoi Sheldon W. Samuels, Industrial Union Department. AFL-CIO. discussed corporate integrity, noting people hired by in dustry "are incapable of objectivity and candor." He called the decision on the purl of major industry not to lure a medical director, or to hire "one who would tell you what you want to hear, is mindless, and stupid." This increases the intensity of the disruption in the workforce, he added. Referring to the United Mules Chamber of Commerce, the National Association ol Manufacturers, Organization Resources Counseluis. ami other similar groups, he said activities ol these oigani/oi ions in the area uf safely and health "border on white eullar crime." Threshold limit values have, in many cases, "been purchased." and "should be proven." lie said. ORC View Leo Teplow. Organization Resources Counselors, Inc.. Washington. D.C.. said business has been so extraordinarily sureessful in some resperts. it should be known that safety and health is n mnjot preoccupation of management. Teplow referred to the similarity of goals between management and uignm/cd labor and noted that "cunfrnntntinn" should be uvuided and replaced by "food for thought." lie said llu- asbestos standard, since it was the first developed by OSIIA. had nn patterns to follow It was important because the issues raised went far beyond one in dustry and one substance He roinmcndrd AIA. noting industry can help bring essen tial facts to hear on OSIIA decisions and "AIA has done this." Johns-Minvlll* Dr Paul Kotin, virc president, health, salely. and environmenl. Jnhns-Manville. said "safe exposure levels exist, if ex posure at certain levels does not increase risk of disease " Industrv accepts the responsibility fur workers exposed to asbestos, including those in the "incubation period." he said. Threshold limit values are maximum allowable eonecn(rations, expressions ol a series of judgments not end points, he said. Industry cannot he satisfied with acceptance ol TIA' s tl tl can he shown that hazards exist, he added In dustry must try to distinguish between fact and opinion in an ollnrl not to rcplieair aliseore of fact over llie next decade vcKocins ran he salely mined, milled, fabricated, and used. 1........ H -"iing that the Al A'will be successful only to the ex it is. aggressive. i.i.l.o .-aid Ihe .i-liesbe; milu-trv should not lure workers on,ike anv Hintr Ilian a "person wilh polio would he hirisl in paint the Golden tiute Bridge. " noting the problems inlieien! in hiring "lugli risk " persons 8005 1252 PRODUCED BY FORD CURRENT REPORT Aabtatoa guleliont Novi Hendry. JtiluivManvillc. said OSH A regulations cfriTl tlir asbestos industry in the ureas nl sprayed asbestos, plasln-s and insulation products aiming other areas. He limed .liiluK-Manvflle is the largest 1.1.S. producer of asbestos tihei ffe said also that the status of (lie usbestos industry ft very, very1 ftoud." Industry Overview liicliard B. Berman, director, labor relations. ll.S. Chamber nl Commerce, said Congress unfortunately relics on the labor committees "who are at the beck and call of the Arunor Asbestos NON-ASBESTIFORM TREMOUTE 16 NOT WITHIN SCOPE OF 06HA A66E6T06 RULE Nonfibrous or non-asbcsliform minerals such as non-nshestiiorm tremolite arc hot within the scope of the ex isting standard for asbestos, according to an interpretation of the standard issued by Assistant Labor Secretary John If. Slender on August 6. The Occupational Safety and llcuHli Administration asbestos standard appears in 29 Code of Federal Regulations. Part l910.93atRcfcrence File 11:51104). Tlie present asbestos standard is written for the purpose of controlling exposures to the fibrous nr asbestiform minerals commonly considered to be asbestos. Slender said. This is reflected in the established permissible limit (nr asbestos air contamination tu which a worker may be expos ed. This is expressed in terms of numbers of fibers in excess of determination or analysis is also expressed as a method lor counting fibers. Talc containing only non-asbeslilorin treinolite is not regulated by the asbestos standard either. Slender said. If only talc and non-fibrous tremolite are present, there is no violation of the asbestos standard Talc containing asbesliforni tremolite nr other fibrous asbestos minerals will be regulated by the asbestos standard, ho added. This interpretation ol the standard refleets the collective opinion of both OSIIA and the National Inslitutr for Oc cupational Safety and Health. Slender said. Agriculture AGRICULTURE STANDARDS ADVISORY COMMITTEE WILL MEET IN WASHINGTON The Standards Advisory Committee on Agriculture includ ing the subcommittees on field sanitation, hand and IHirlable tools walking and working surfaces, and ladders, mil mccl in Washington, U.C on September 24-25. The meeting will hegm at 9 a m each day in room 107 ADC. Mam l,,ihor Building Constitution Ave.. at 14th St NW The meeiing is open In the public. The agenda provides lor the full committee in meet in an intrndmiurs M -sinn each day after which the ubeomniiii<-r Hill mccl in separate sessions. The subcommittees will 'uniinuc deliberations from previous meetings The suhi iimmitter on ladders is meeting lor the first tune and will begin deliberations Inward recommending a si.rnIl.iid as Slum a, the unhung and working surfaces su*v<v. miltee eumpleie- a hrirl meetT- on the lirsl day The t-" riniumtler d| reennveiu- In ref'' /e anil cun-ider any <i'l hU'inesy pending before the r`'i..,:iiUco ATTACHMENT 9/19/74 439 Any written data or views concerning the subjects to be considered which arc received by the committee manage ment office before the dale of the meeting, together with 20 duplicate copies, will be given to the members and Included In the record of the meeting. Persons wishing tu orally address (he committee at the meeting should submit a written request tu be heard, in cluding the subject on which they will speak, as well as an es timate of Hie amount of time requested and the capacity'in which they will appear. Such information should be addressed to Jeanne W. Femme, committee management ofiieer, 1725 M St.. NW, Room 200, Occupational Safety and Health Administration, Washington, U.C. 20210, tel. 202 ' 961-2248,2487. Kentucky FEDERAL REPORT RECOMMENDS CONTINUED PLAN APPROVAL. NO FEDERAL FORCE CHANGE The federal evaluation report nl Kentucky's first six months of operations under an approved job safety und heallh plan recommended continued plan approval, but nn reduction of federal forces in the stale for the second sixmonth prriuit ul operations. The slate accomplished developmental steps during the first six months of npr-rations as set nut in the state plan ap proval notice iReference File 8l:(i(l(Ui "There does not appear to he any problems or deficiencies with (he plan which would cause an unfavorable drlermination at this lime" under Section IBlci of the Occupational Safety and Health Act. the repurl nnied. The rrpoil lists a xummary id findings noted during August I. )97:i. through Januaiv SI. 1974. It focuses on the entoreemeni activities of the stale based on review and evaluation id 2U!> ease files of the state department of labor and on 32 case files of the state public service commission. In addition, observations and subsequent recommen dations for the department of lalior and the public service commission resulted irnm general discussions with the state, review u( the plan, and an on-slte visit conducted from March 2a to March 29. 1974. Departmanl Dahcienciet Deficiencies in the department of labor were noted for lapse of time between date of inspection and dale of citation issuance, avciage proposed penalties for nonserious violations, distribution of inspections, and use of electrical standards Minor problems also were noted regarding employer invnlvcmrnl in inspections, insufficient documentation of case files, and inaccurate gravity classifications The report nlsu noted tailings by the public service com mission to meet Icdcral criteria in the areas of inspection geographic spicad. employee involvement in insperliun' riling of violations with appropriate standards, and the numhci nl inspections carried oul per monlli per man. The rommissinn has ir*|ion.sibiliiy for adininisir.-itiun of the state plan lur utilities under its jurisdiction Problems in the slate department ol occupational health centered around the scheduling ut health hazard inspections Wiramrv support, provisions for radiation hazard proteiImn. and hazard abatement dates, the repnit noted Hu- repmt also observed problems and addressed rernniiiicnd.iiiun-. to Hie state's compliance vllicer training wnguin. list- >! jut) safely and heallh resources the nimagement inh-rinnUnn system and processing ul stan dard* inlcipn-ljlums and clarifirations Cfcl.r<' 197a I.) Iht bui"ii *1 Hoi'Ortol Alljm, 8005 1253 PRODUCED BY FORD The Aslieslns Information Axsnrialion/Nnrlli Amcrira has suggested revision of the asbestos standard to include a limit of 10 filters, lunger than 5 micrometers jior cubic centimeter of air as determined oset a 10ntimile priind. as well as work practices for the nslrestos industry. In a letter to Daniel P. Iloyil. Direrlor of OSIIA'x Office of Standards Development,rlalerl July IS. Roiiori II. Merciless, executive rlireclor of the Association, wrote: "We can report that there is an industry-wide appreciation of the health problems associated with asbestos dust in the workplace, requirin': realistic understanding and remedial aelion where necessary." 'Ilie reeommeiidaiions were prepared hy the Association's Standards and Technical Committee composed of environmental ronlrol engineers, industrial hygienists and safely and health directors, to assist OSH A in its review and possible revision of the standard hy early next year. (in the question ol ceiling concentration, the Association's recommendation is as follows: *'No employee shall he exposed to aiiiiorne ronecnliaiions of nsliestos fillers in excess' of 10 fibers, longer Ilian 5 micionicicix, per riihic centimeter of nir, as determined over a lO-ininotc period hy the method pre scribed. .Its recommendation would delete the requirement of exposure "at any lime" and insert "over a 1 Ia ixArifwl * I i concentrations of asbestos filter in excess of (lie exposure limits prescribed in paragraph (hi of this section nilI be released." Work practices offered by Hie Association for OSIIA's review include: unloading and storing bagged nslK'.s'tos filter; introduction of asbestos fiber into manufacturing processes: asbestos dust and scrap removal and disposal: anil housekeeping in the asbestos industry. The committer is headed hy lulmuml M. Pctincr, Director of Environmental Control for Jolinx-Manwlle. Other member:: Harold L. Ih'ckcr. Chief Engineer. Nicolet Industries, Ambler, Pa.; Charles C. Clarke. Industrial Hygienist. Mcndix C nrp.. Southfield, Mirli.: C. Nelson Codding, Corporate Environmental Control. Jim ('alter Research Corp.. fit. Petersburg. Ha.; William Fassoliotis. Diieetor of Safely and Sennit). (1AF Corp . N'cw York. N.Y.; John P. Me( m.ley. Director of Manufacturing. Asbestos Cement Pipe A Plasties, Ccrlaiu-teed Products Corp., Ambler. Pa.; I..i\ Moody, Plant I nginccr. Southern Asliestos Co.. Charlotte. N.C.; I laser Morton. Indus trial l.nginrer. ( on-.dcom Industries. Inc., tiiikxhiug. Md.; William II. Morlonson. General M.iniilaelmine M.magci. Flintl.nl" t o.. 1.. Potlu-rfoid. N.J.; tir. I I d. Rhodes. Area Manager. Marketing and 1 ivli indue; . I ninn ( arhiite. N'iag.u i I all.. N Y.: Isaac II. Weaier. Director of Enwmnim-ntal Control, Uayhesl'is-Maidialtan. Inc.. Iiuudiull ( .mo . I i.mk II. /immcrnv.m. Cmpot.tie liiieeloi. Safely and I uviioiiniental lle.dth.Natioo.il Cxpsinn t u.. Ibill.do. fs Y. PRODUCED BY FORD AMERICAN SOCIETY FOR TESTING AND MATERIALS Task Group Letter Ballot: Issue date Deadline for receipt 11 Oct 1974 11 Nov 1974 Task Group on Naturally Oecurlng Inorganic Fibers of ASTM Cosnlttee E-34 Information and Instructions 1. Return of this ballot Is required from members even If not prepared, of qualified, to vote affirmatively or negatively on any Item. In such cases the 'ABSTAINING' column should be checked. 2. When voting 1AFFIRMATIVE' or 'NEGATIVE' a member must Indicate his classification as a Producer (P), User (U), or General Interest (GI), with respect to each item, and not necessarily with respect to his classification on the committee. 3. Negative votes and any consents must be accompanied by an explanation (on a separate sheet) In order to be considered. Include proposed specific changes when applicable. PRINT NAMERETURN one copy of COMPANY ________ _ ballot to: DATE_____ SIGNATURE M. Cossette Recording Secretary QAMA Laboratory University of Sherbrooke Sherbrooke, P.Q., Canada J1K 2R1 Keep white one for your records. 8005 1255 PRODUCED BY FORD AMERICAN SOCIETY FOR TESTING AND MATERIALS Task Group Letter Ballot: Issue date Deadline for receipt 11 Oct 1974 11 Nov 1974 Task Group on Naturally Occurlng Inorganic Fibers of ASTM Committee E-34 Information and Instructions 1. Return of this ballot la required from members even If not prepared, of qualified, to vote affirmatively or negatively on any Item. In such cases the 'ABSTAINING' column should be checked. 2. When voting 'AFFIRMATIVE' or 'NEGATIVE' a member must Indicate hie classification as a Producer (?), User (U), or General Interest (Cl), vith respect to each Item, and not necessarily with respect to his classification on the committee. 3. Negative votes and any consents must be accompanied by an explanation (on a separate sheet) In order to be considered. Include proposed specific changes when applicable. PRINT NAMERETURN one copy of COMPANY ____________ ________ ballot to: DATE_____ SIGNATURE M. CosBette Recording Secretary QAMA Laboratory University of Sherbrooke Sherbrooke, P.Q., Canada J1K 2R1 DEFINITION asbestiform_ asbestos____ fiber_______ fibril fibrous particulate naturally-occurlng mineral fiber. AFFIRMATIVE I U Cl NEGATIVE U GI ABSTAINING Keep white one for your records. 8005 1256 PRODUCED BY FORD Document Ho. 26 11 October 1974 Mlneraloglcel Definition* of Term* Relating to Naturally Occurlng Inorganic Fiber* aBbeatlform - mineral structured in the form of asbestos asbestos - generic term for naturally-occuring inorganic hydrated silicates that, when processed separate into fibrils. Mineral* defined a* asbestos are the asbeatlform varieties of the following; serpentine (ehrysotlle), rlebecklte (crocldollte), cuamingtonlte (amoslte), anthophylllte, treaollte, end actinolite. fiber - for the purpose of this standard, fiber swans naturally-occuring inorganic fiber. fibril - a single crystal in the form of a fiber. fibrous particulate - for the purpose of this standard, fibrous particulate designates fibers, fiber fragments and fiber agglomerates. naturally-occuring Inorganic fiber - form of mineral characterised by properties of flexibility and length-to-vidth ratio in the order of 100, composed of definite crystal unit cells oriented with respect to a specific axis. Note 1 - The designated 100:1 aspect ratio is considered to represent a reasonable lower limit for naturally-occuring mineral fibers. Fibers of these dimensions can be broken into parts of fibers that may maintain their eame surface properties and activities. Therefore fiber fragments may have to be evaluated for atmospheric monitoring purposes. However, attempting to define a fiber by its aspect ratio alone is inadequate since it is obvious that particles of non-flbrous mineral do not become fibers as their aspect ' ratio increases through comminution. 8005 1257 PRODUCED BY FORD 1. RECOMMENDATIONS FOR AM ASBESTOS STANDARD The American Society for Testing and Materials (ASTM) recoamends that worker exposure to airborne asbestos particulates In the workplace be controlled by requiring compliance with the following sections. This standard Is based upon the best atmospheric sampling techniques currently available but It is acknowledged that these are not as precise and accurate as desired. This, standard is subject to review and will be revised as needed. Section 1 - Environmental (work place air) (a) Concentration The concentration of airborne asbestos particulates shall be controlled so that workers are not exposed to concentrations exceeding tbe following values: Type of asbestos mineral Monitoring Method* Membranei Filter Midget Implnger Avg (TWA). Peak 3 Avg(TWA) Peak fibers/ctr fibers /cr> mppcf mppcf Rlebecklte (crocldollte) Other varieties of asbestos *5 5^ 10 28 5 10 >Membrane filter; based upon a count of fibers greater than 5 micrometers In length determined by the mes&rane filter method at 400-450X magnification with a 4 millimeter objective and phase contrast Illumination, as described In Appendix 1. 8005 1258 PRODUCED BY FORD Midget loplnger; bated upon a count of airborne partlclea collected by the nidget lnplnger aethod aa deacrlbed In Appendix 1. Time-weighted average (WA) eaposure for an 8-hour work day. Peak concentration determined by a alnimua aaapllng tine of 10 mlnutea. (b) Stapling Procedures for sampling, calibration of equipment and analyals of asbestos samples.by either the Membrane Filter or Midget lnplnger Methods, shall be aa described In Appendix 1. Atmospheric monitoring records shall be kept at least three years. Section 2 - Medical Medical surveillance shall be exercised aa described on all workers exposed to airborne asbestos particulates. For the purpose of this requirement the term 'exposed to airborne asbestos particulates refers to exposures attaining 20 percent of the limits listed In 6ectlon 1 for various types of asbestos. The primary objective of this surveillance is to accumulate reliable exposure response data. A secondary objective la to provide guidance for medical mansgement of individuals vltr, i,..ow evidence of reaction to past exposure, either due to excessive exposures or hypersusceptlblllty. However, It Is acknowledged that the current state of medical knowledge may not permit successful medical management of such cases beyond therapy for complications of ailments associated with asbestos exposure. Medical survellance cannot be a guide to adequacy of current controls when medical and environmental data cover only the recent work experience because of the prolonged exposure required for the manifestation of sympthoma related thereto. Required components of a medical survellance program include annual measurements of pulmonary function Including; forced vital capacity (FVC), and forced expi ratory volume for one second (FEV.), and annual chest roentgenograms (posteroanterlor 14 x 17 inches). Additional medical requirement components Include a history to quantify .taking habits and to describe details on past exposure to pulmonary hatards and carcinogens, and to determine the presence of absence of pulmonary, cardiovascular, and gastro Intestinal sympthomB. A physical examination constitutes and additional required component of medical survellance, with particular attention to pulmonary rales, and clubbing of fingers. Chest roentgenograms (X-Rays) and pulmonary function testa will be performed at the employer's expense annually. Preplacement medical examinations and medical examinations on the termination of employment of exposed workers are also required. 8005 1259 PRODUCED BY FORD 3 Medical records shall be retained by employer* for at least SO years. Section 3 - Labeling (a) A warning label for asbestos as shown hereunder shall be used. CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST Breathing Asbestos Dust Hay Cause Serious Bodily Harm (b) The warning label shall appear on all containers of asbestos or materials containing loose asbestos. (c) Materials containing asbestos that are shipped without containers shall be individually labeled except as provided hereunder: (I) Items that may be marred by labels may be shipped with Interleaved labels held in place by the pressure of the Items in question. (II) Materials containing asbestos that la so efficiently bound as to prevent the release of fiber concentrations exceeding limits stated in Section 1 (a) during manipulation and shaping by foreseable methods, may be exempt from labeling requirements. (III) Materials containing asbestoB bound, or reacted, In such a way as to give off emanations of dust that can be demonstrated to be non-toxic, when produced by foreseable activities, may be exempt from labeling. Section 4 - Personal Protective Equipment This section shall apply under emergency conditions and during periods when limits are exceeded due to unforeseen occurence's. Use of respirators must be decided on the basis of peak concentration. When the limits of exposure to asbestos dust prescribed In paragraph (a) of Section 1 are exceeded, the program of respiratory protection described In subsection (a) of this Section, must be put into effect for every worker exposed. (a) Respiratory Protection (1) For the purpose of determining the class of respirator to be used, the employer shall measure the atmospheric concentration of airborne asbestos particulates In the workplace whenever process, worksite, climate or control 8003 1260 PRODUCED BY FORD changes occur which are likely to affect the asbestos concentration. The employer shall test for respirator fit or make determinations of asbestos particulates within the respiratory inlet covering to Insure that no worker Is being exposed to asbestos in excess of the standard either because of Improper respirator selection or fit. * (11) As noted above, the use of respirators can be decided on the basis of peak concentrations, as tabled hereunder: . Types of Maximum Peak Concentration Asbestos Membrane Filter (fibers/cm-*) Midget Impinger (mppcf) MineralClass A Class B Class A Class B Riebecklte (erocidollte) 25 250 30 300 Other varieties of asbestos 50 500 50 500 (111) For peak concentrations exceeding the limits given in Section 1 (a) but not exceeding limits given for class A above in Section 4 (a) (11), a reusable or single use filter-type air-purifying respirator, operating vlth a negative pressure during the Inhalation phase of breathing, approved under the proviri'.-n ot 30 CFR 14 (Bureau of Mines Schedule 21B) or valveless respirators provldng equivalent protection shall be used. (lv) For peak concentrations not exceeding class B given In Section 4 (a) (11), a powered alr-purlfylng positive-pressure respirator approved under the provision of 30 CFR 14 (Bureau of Mines Schedule 21B) shall be used (v) For atmospheres with peak concentrations greater than Claes B as given in Section 4 (a) (ill), e type C positive-pressure supplied air respirator approved under the provision of 30 CFR 12 (Bureau of Mines Schedule 190) shall be U6ed. (vl) The emplyer sb*',l establish a respirator program in accordance with the requirements ot the American National Standard for Respiratory Protection Z88.2 - 1969. (b) Special Clothing (1) The employer shall provide, and enforce the use of, special whole body clothing, head coverings, gloves, and foot coverings for any employee exposed to airborne concentrations of fibrous asbestos particulates which exceed the ceiling level prescribed In Section 1 (a) . 8005 1261 PRODUCED BY FORD -5- (ii) Clothes lockers: The employer shall provide two separste containers for each employee exposed to concentrations exceeding limits stated in Section 1(a), to prevent contamination of the employee's street clothes from his work clothes. (Ill) Laundering: Laundering and maintenance of clothing supplied by the employer shall be the latter's responsibility. The employer must ensure that handling, transportation and laundering are carried out In such a way as to prevent dust concentrations In excess of limits stated in Section 1 (a). Section 5 - Apprise! of Employees of Hazards from Asbestos Each worker exposed to airborne asbestos particulates shall be fully apprised of all hasards, relevant symptoms and proper conditions and precautions concerning use, handling or exposure. Each exposed worker shall be Informed of the Information that Is applicable to a specific product or material containing five percent or more asbestos (see Appendix LLL for details of Information required). The Information shall be kept on file and made available to any exposed worker on verbal request, at all work locations where the concentration of airborne asbestos particulates exceed one half of the limits given In Section 1(a). It Is recommended, but not required, that this Information be provided wherever workers are exposed In any way to asbestos. Information as specified In Appendix III shall be recorded on U.S. Department of Labor Form OSHA-20, 'Material Safety Data Sheet', attached hereto, or a similar form approved by the Occupational Safety and Health Administration, U.S. Department of Labor. Section 6 - Work Practices 8005 1262 PRODUCED BY FORD 6 Section 7 - Monitoring and Recordkeeping Requirements Employers are required to maintain records of environmental exposure to airborne asbestos particulates for at least three years. Personal exposure samples will be collected at least annually for specific maximum-risk work operations. These selected samples will be collected and evaluated as both tlme-velgted and peak concentration values. The personal sampling regime shall be on a quarterly basis for maximum-risk work areas when environmental concentrations are in excess of the standard. Records of the type of respiratory protection in use, and of the duration of each usage during the quartely sampling schedule must also be maintained. Quarterly sampling, monitoring and record keeping are required only until environmental levels comply with the standard. 11. INTRODUCTION 2.1 This document presents the crlterls and standard based thereon for the prevention of occupational diseases associated with exposure to asbestos. 2.1.1 The data referred to herein is available on loan from ASTM Headquarter.-. 2.2 The goal of this standard is to prevent significantly diminished functional capacity, or life expectancy, among workers as a result of their work experience, insofar as practicable. 2.2.1 This standard is Intended for occupations covered by the Occupational Safety and Health Act of 1970 to the specific exclusion of those covered by the Federal Metal and Nonmetalllc Mines Safety Act (30 US. C. 725 et seg.). 2.3 These criteria were developed to ensure that the standard based there on would satisfy *-he following conditions: 2.3.1 Protect workers against diseases related to asbestos exposure. 2.3.2 Applicable by means of available monitoring methods. 2.3.3 Possible with existing technology 2.3.4 Feasible economically 8005 1263 PRODUCED BY FORD 7 2.4 These criteria and the standard based thereon are for the most part taken from previously published criteria and standards, and particu lar? from those published by the National Institute for Occupational Safety and Health (NIOSH) in 1972. Other criteria vere taken from the following sources: 2.4.1 International Labor Office (XLO): Report on Meeting of Experts on the Safe Use of Asbestos, 11-18 Dec 1973. 2.4.2 International Agency for Research of Cancer (IARC): Report of the Advisory Committee on Asbestos Cancers to the Director of the International Agency for Research on Cancer. 2.4.3 National Research Council (NRC) of Canada: Report of the Committee for Scientific Criteria for Environmental Quality (not yet published, probable title: Asbestos in the Canadian Environment). 2.4.4 In addition, criteria were based upon new data, and upon new interpretations of data considered in previous documents. 2.5 This standard and criteria based thereon differs from previous documents on the following points: % 2.5.1 Asbestosis is the only disease related to asbestos exposure for which available environmental and epidemiological data Is consi dered sufficient for basing a threshold limit value. Although a dose-response relationship between asbestos exposure and va rious neoplasia cannot be discounted In view of the paucity of data available, neither can such a relationship be recognised on scientific grounds as opposed to Intuitive judgement. 2.5.2 It is recognised that the asbestlform variety of rlebecklte (crocldollte) Is associated with different degrees of hasard and separate threshold limit values are proposed for this variety. 2.5.3 Available sampling methods are recognised as not entirely adequate. In particular the method based upon a membrane filter, stipulated by NIOSH, is considered advantageous with respect to ibe'exclusion of non-flbrous particles and disadvantageous with respect to reproducibility. On the other hand, the midget lmplnger method Is considered advantageous because much of the long term environmental data available was based upon this method, and disadvantageous to the extent that non-flbrous particles are Included. Accordingly both methods are endorsed, with separate threshold limit valueB corresponding to each method. 8005 1264 PRODUCED BY FORD APPENDIX A I4 Document No. 15 fNOAIM UfMCA A- SB--E---S--T--O---S----I-N' FOR---M--A-T..I.O...N....A..^SSOCIATIONi 1660 L Street. N.W. / Wathmpion. D.C 200J6 / (302) 2234d5 . .15 July 1974 . _. . .. , Dr. Daniel P. Boyd . . Director, Office of Standard Development Occupational Safety and Health Administration 1726 M Street, N.W. . Washington, D.C. 20036 ` Dear Dr. Boyd: ' ' `- The Asbestos Information Association/North America consists of twenty-two member companies and associations which represent three-quarters of the asbestos mining, milling, manufacturing, and importing industry of the United States. The Association maintains active liaison with trade and technical groups related to the industry. Over a period of time and on numerous occasions, we have consulted with key representatives within the Occupational Safety and Health Adminis tration in a cooperative effort to develop sound safety a<iu health regulations for the industry. Wo are pleased to enjoy a close working relationship with OSHA. A. VThen the Association learned of plans to revise the Asbestos Standard, as first published in the Federal Register, Vol. 37, : No. 110, June 7, 1972, we spoke with Mr. Lewis Cox, Mr. Gerald Scannel and Dr. John P. O'Neill to advise that we would be pleased to take on the task to recommend revisions and develop work prac- . tices. We submit, herewith; our recommendations for revising the OSHA Asbestos Standard, as reprinted in the Federal Register, Vol. 39, No. 125, June 27, 1974. We also enclose suggested*work prac tices in the following areas: . A. Unloading and Storing Bagged Asbestos Fiber. B. Introduction of Asbestos Fiber into Manufacturing . Processes. , . C. Asbestos Dust and Scrap Removal and Disposal. D. Housekeeping in the Asbestos Industry. . Please note that we have addressed only those areas where the Association feels the necessity for clarification or betterdefined practical application in the interests of ready compliance within the spirit of the Act. Areas not addressed are considered ACAD aKI ^ *> *1 **** 8005 1265 PRODUCED BY FORD Page -2 - '' .. - The Association's Standards and Technical Committee, assigned to the task of preparing revisions and work practices, consists of environmental control engineers, industrial hygienists, and safety and health directors. The Committee has consulted extensively with medical, management, labor and othe:: disciplines within the industry. Edmund M. Fenner of the Johns-Manville Corporation serves as chairman of the Committee. Mr. Fenner is well known for his many years of experience in the occupational safety and health field. He is a regular member of the lecturing staff for NIOSH and participates in numerous national technical programs on occupa tional safety and health as concerns the asbestos industry. A list of other members -of the Committee is attached. t ' The Association acknowledges the importance of disseminating information concerning asbestos regulations and work practices throughout the industry and is performing this function. Much has been done and much more will be done. We are proceeding with the development of work practice materials for member customers who are * fabricators and processors of asbestos fiber and fiber-containing products. . We can report that there is an industry-wide appreciation of the health problems associated with asbestos dust in the workplace, requiring rea/ listic understanding and r,emedial action where necessary. We are indebted to Or 0-Neill and Mr. Harry Gilbert for their out standing assistance and professional guidance. We shall be pleased . to meet with you or representatives of your office to discuss our recommendations and any other matters at your pleasure and conven ience. . . .t JIHM/eg Enclosures: , . . (1) Recommendations for Revision, OSHA Occupational and Health Standard for Exposure to Asbestos Dust (2) Suggested Workplace Practices in the Asbestos Industry ' 8005 1266 PRODUCED BY FORD . STANDARDS AND TECHNICAL COMMITTEE ` ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA Edmund M. Fenner Chairman 1 Director Environmental Control Johns-Kanville Corporation Denver, Colorado Karold L. Becker . Chief Engineer Nicolet Industries , Ambler, Pennsylvania . . ' * L. E. Moody Plant. Engineer ' Southern Asbestos Company Charlotte, North Carolina Charles C. Clarke ' Industrial Hygienist . The Bendix Corporation Southfield, Michigan .. Fraser Morton Industrial Engineer Conqoleum Industries, Inc. ` Finksburg, Maryland . C. Nelson Codding . Corporate Environmental Control Jim Walter Research Corporation St. Petersburg, Florida ' Yfilliam H. Mortonson ` General Manufacturing Manager The Flintkote Company East Rutherford, New Jersey Sudhakar Dixit ! Industrial Engineer .Garlock, Incorporated . Palymyra, New York Dr. H. B. Rhodes ' ' Area Manager ' Marketing and Technology ' Union Carbide Corporation . Niagara Falls, New York I. William Fassuliotis ..... : Director Safety and Security Isaac H. Weaver ' GAF Corporation * ... Director Environmental Control New York, New York Raybestos-Manhattan, Inc. Manheim, Pennsylvania John P. McGinley 1 Director of Manufacturing Asbestos Cement Pipe and Plastics Certain-teed Products Corporation Ambler, Pennsylvania . Frank H. Zimmerman '' Corporate Director, Safety and Environmental Healt National Gypsum Company Buffalo, New York 8005 1267 PRODUCED BY FORD RECOMMENDATIONS FOR REVISION CSKA'OCCUPATIONAL SAFETY AND HEALTH STANDARD * . . ' ' - EXPOSURE TO ASBESTOS DUST Prepared by ; . ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA 4 . *. f. . ' * . ' " 1 . ENCLOSURE (1) 8005 1268 PRODUCED BY FORD [M 910.93a Asbestos '' ', .. . (a) (3) Ceiling concentration ', ^ ` Recommended chance: ' 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, as determined over a 10-minute period-by the method pre- scribed in paragraph" (e)" of this section. Revision to read: . No employee shall be exposed to airborne concentrations- of asbestos fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined 1 over a 10-minute period by the method prescribed in paragraph (e) of this section. ... Reason: . . ' .. Limitations of the monitoring procedure make it impossible to determine instantaneous peak exposures, A 10-minute sampling period is a practical minimum. I Note* Phrases in parenthesis are deletions. Phrases underlined are additions. 8005 1269 PRODUCED BY FORD 1910.93a Asbestos (c)__ (1) (ii) (a) Local exhaust ventilation . Recommended change: ; '. ' ., . _ Local exhaust ventilation and dust collection systems ' " ................ANSI Standard Z9.2 - 1971 and American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems for the .Control of Asbestos- Cortainihg"Ousts, Ah'SI z9.5 - 1974, wnicn are incorpo rated by reference herein, or the equivalent. Revision to read; . . -V . ' Local exhaust ventilation and dust collection systems shall be designed, constructed, installed, and maintained in accordance with the American National Standard Funda mentals Governing the Design and Operation of Local Exhaust Systems, ANSI 39.2 - 1971 and American National # ' Standard Fundamentals Governing the Design and Operation * of Local Exhar.v^ Systems for the Control of Asbestos- Containing Dusts, ANSI Z9.5 - 1974, which are incorporated by reference herein, or the equivalent. Reason: ` ... .' ' The Standards and Technical Committee of the Asbestos Information Association/North America has drafted A2\'SI Standard Z9.5 - 1974. It is anticipated that this standard will be issued prior to the promulgation of the revised Asbestos Standard .. . . Dust control systems can be designed to accomplish the reduction of asbestos fiber levels with less than full adherence to the ANSI design standards. . . ' # Note: Phrases underlined are additions. 4 8005 1270 PRODUCED BY FORD 1910.93a Asbestos (c) (1) (iii) Particular tools Recommended change: ' . Insofar as practicable, all hand operated and power ' operated tools which in any reasonable foreseeable use may produce or release asbestos liners in excess ............... shall be provided with local exhaust systems in accordance with subdivision (ii) of this subparagraph. Revision to read: .' . Insofar as practicable, all hand operated and power operated tools which in any reasonable foreseeable use may produce or release asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section, ' such as, but not limited to, saws, scorers, abrasive wheels, and drills, shall be provided with local exhaust ventila tion systems in accordance with subdivision (ii) of this subparagraph. . Reason: ` * . . There are certain work situations in which it is not feasible to equip portable tools with dust control equipment. y}.4e use 0f the phrase "in any reasonable foreseeable use" . is in keeping with other portions of the OSHA Standard. Motet' Phrases underlined are additions. 4 .. 8005 1271 PRODUCED BY FORD 1910.93a Asbestos (c? (2) (ii) Particular products and operations . %. Recommended change; . *. . * . ` ' No asbestos cement............... . or similar material containing , asbestos shall be removed from bags, cartons or other ' containers in which they are being shipped without being either wetted or enclosed or ventilated, or otherwise handled so as to prevent effectively ............... Revision to read: '. . ` No asbestos cement, mortar, coating, grout, plaster, or similar material containing asbestos shall be removed from `bags, cartons or other containers in which they are being shipped without being either wetted, or enclosed, or ventilated, or otherwise handled so as to prevent effec tively the release of airborne asbestos fibers in excess . of tne limits prescribed in paragraph (b) of this section. Reason: ' : . " ' There may be work practices in addition to those presently specified which may effectively accomplish the purpose of this subparagraph. : . . Note: Phrases underlined are additions.- .4 < 8005 1272 PRODUCED BY FORD 1910.93a Asbestos (c) (2) (Iii) Spraving, demolition or removal ' .. . . ' . Recommended change - Add sentence: .. "Whore products that have been modified by a bonding agent, ......... coating, binder or other material so that during, spraying, - demolition or removal, no airborne concentrations of asbestos fibers in excess of the allowable exposure limits will be released, these provisions do not apply." . .. Revision to read: * Employees encaged 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 insulation or coverings shall be provided with respiratory equipment in accordance with paragraph (d) (2) (iii) of this section and with special clothing in accord * ancc with paragraph (d) (3) of this section. Where products . that have been modified by a bonding agent, coating, binder . . or other material so that during spraying, demolition or , removal, no airborne concentrations of asbestos fibers in . excess of the allowable exposure limits will be released, ` these provisions do ihot apply. * ., Reason: ' ' .' . .' . There are materials containing asbestos which can be applied .;. .by spraying without generating airborne concentrations of . asbestos fiber in excess of allowable limits. - 4 I 8005 1273 PRODUCED BY FORD 1910.93c Asbestos (d) (1) Personal protective equipment . . Revision to read; .. . ' Compliance with the exposure limits prescribed by para graph (b) of this section may not be achieved by the use of respirators or shift rotation of employees, except: T ' ' - - - Tfi> During the time period necessary to'install the '**" engineering controls and to institute the work practices * required by paragraph (c) of this section; (ii) In work situations in which the methods pre scribed in paragraph (c) of this section are either tech nically not feasible or feasible to an extent insufficient to reduce the airborne concentrations of asbestos fibers below the limits prescribed by paragraph (b) of this section; (iii) In emergencies; ... ' (iv) Where o-orations involve only occasional handling of small quanwiLies of asbestos fiber, e.g. twice each 8-hour ' shift or less, ana provision of engineering control would impose an unwarranted financial burden; . (v) Where both respirators and personnal rotation are allowed by subdivisions (i), (ii) , or (iii) of this subparagraph, and both are practicable, personnel rotation ; shall be preferred and used; or " (vi) Where respirators are permitted under subdivision -r(iv) of this subparagraph, their use shall be subject to the following limitations: .. 1. Respirator shall not be worn for more than 60 minutes in any 8-'nour shift. '9 2. Respirator shall not be worn for more than 30 minutes in any hour in the 8-hour shift. * 3. Exposures do not exceed 10 times the permissible limits and protection can be achieved by use of an air purifying respirator. ' . * 8005 1274 PRODUCED BY FORD 1510.93a Asbestos * .* ' .?<* * (f) (2) (ii) Sampling frequency and patterns ' (f) (3) (ii) Sampling frequency and patterns ;. .. Recommended change: *. . . > .' After the ............. , samples shall be of such frequency and ' pattern as to represent with reasonable accuracy the levels of exposure Of the employee. Monitoring is not required ' during usage of products where asbestos fibers have been modified by a bcncing acrenr, coarincr, binder, or other material so uhau ciurinc anv reasonable foreseeable use, handling, storage, tiisposai, processing or trar.sporrazion, no airborne cor.canrraricns of asbestos fiber'in excess of the exposure li-.irs prescribed in yaragraon (b) of this section will os released. In no case shall the sampling .............. prescribed in paragraph (b) of this section. ' ' Revision to read: . .. . '' 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 the`employee. Monitoring is not ' required during usagfe of products where asbestos fibers have been modified by a bbnding agent, coating, binder, or other material so that during any reasonable foreseeable use, . handling, storage, disposal, processing or transportation, no airborne concentrations of asbestos fiber in excess of the exposure limits prescribed in paragraph (b) of this section will be released. In no case shall the sampling be done at intervals greater them 6 months for employees whose exposure to asbestos may reasonably be foreseen to ' exceed the limits prescribed by paragraph (b) of this section. . * . Reason; ' . . ' * Monitoring should not be required in those situations where significant quantities of airborne asbestos fiber.are not released. -- . Koto:.4Phrases underlined arc additions. 8005 1275 PRODUCED BY FORD 1510.53a Asbestos (h) (2) VJaste disposal ' .. ' Recommended chanoe: . ' ' ' v '"Asbestos waste, scrap....... shall be. collected and disposed. _ of in sealed (impermeable) plastic bags or other closed . (impermeable) containers. . Revision to read: ' Asbestos waste, scrap, debris, bags, containers, equipment, and asbestos-contaminated clothing,consigned for disposal, which may produce in any reasonably foreseeable use, handling, storage, processing, disposal, or transportation airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section shall be collected and disposed of in sealed plastic bags or other closed containers. . Reason: ' . ' . ' ' The objective of this subparagraph is to prevent the release of airborne concentrations of asbestos fiber over the per.-? . . nissible exposure limits during waste disposal. The word "impermeable" is highly restrictive and not necessary to fulfillment of the intent through use of "sealed plastic bags or other closed'containers." Note: Phrases in parenthesis are deletions. . Phrases underlined are additions. 4 8005 1276 PRODUCED BY FORD I. 1510.33a Asbestos . ., .. . . . (l) (2) (3) '(4) Medical examinations * Recommended change to each subparagraph; ............... airborne concentrations of asbestos fibers (in excess of one-half the exposure limits specified in section . (b) of this standard) 7777777 '' "' ' Revisions to read: ` . ` ': - V 1 ' . (2) ^replacement. The employer shall provide or make - available to each of. his employees-, within 30 calendar days .following his first employment in an occupation exposed to airborne concentrations of asbestos fibers, (in excess of one-half the exposure limits specified in section (b) of this - "standard), a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (posterior . anterior 14 x 17 inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory . volume at 1 second (FEV .>). . ' (3) Annual examinations. On or before January 31, 1973, . and at least annually thereafter, every employer shall . provide, or make available, comprehensive medical examina- ' tions to each of his employees engaged in occupations exposed - to airborne concentrations of asbestos fibers {in- excess* uf . one-half the exposure limits specified in section (b) of this standard). Such annual examination shall include, as a ' minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches! . ` a history to elicit symptomatology of respiratory disease, and ' pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEV.o). ' {<) Termination of employment. The employer shall provide, or make available, within 30 calendar days before or after the . termination of employment of any employee engaged an occupa- . tion exposed to airborne concentrations of asbestos fibers (in ' excess of one-half the exposure limits specified in section (b) of this standard), a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (posterior ' anterior 14 x 17 inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to include '. forced vital capacity (FVC) and forced- expiratory volume at I second (FEV-). .. . Reason: . '. This is consistent with KlOSJi recommendations. Present wording in these subdivisions does not adequately define when medical examinations should be provided or made available. Strict interpretation of the standard, as now written, could result in medical examinations in instances where unnecessary. icote riv,*nr.es underlined ore additions. 8005 1277 PRODUCED BY FORD 1910.93a Asbestos (j) (S) (li) Access . Reconunended change: ' . 1-.-.. . ..... " ........ . . The contents ................ to authorized physicians and medical consul- tants of either of them, and, upon the written request of an ' employee or former employee, to his physician....... Revision to read: . ` .. . ' The contents of the records of the medical examinations required by this paragraph shall be made available, for inspection and copying, to the Assistant Secretary of Labor for Occupational Safety and Health, the Director of NXOSH, to authorized physi cians and medical consultants of either of them, and, upon the written request of an employee or former employee, to his physician.* Any physician who conducts a medical examination . required by this paragraph shall furnish to the employer of the examined employee all the information specifically required by this paragraph, and any other medical information related . to occupational exposure to asbestos fibers. Reason: . . .' Practical and prudent!procedure is best served by requiring that requests by employees or former employees for medical records be in writing. . . . . .' Note: Word underlined is an addition. .4 8005 1278 PRODUCED BY FORD SUGGESTED WORK PRACTICES OSIIA OCCUPATIONAL SAFETY AND HEALTH STANDARD . EXPOSURE TO ASBESTOS DUST ' ' i A. , Unloading and Storing Bagged Asbestos Fiber B. Introduction of Asbestos Fiber into Manufacturing . Processes ............ ... C. Asbestos Dust and Scrap Removal ana Disposal D. Housekeeping in the Asbestos Industry Prepared by '' ' ASBESTOS INFORMATION- ASSOCIATION/NORTH AMERICA .i ENCLOSURE (2) 8005 1279 PRODUCED BY FORD 1 APPENDIX 4 Document No. 16 UNLOADING AND STORING AGGSD ASBESTOS FIBER 1. Prior to unloading bagged asbestos fiber from a boxcar . . or truck, a visual inspection of the cargo shall be 'made to determine if bag damage' has occurred and the extent of loose fiber present, if any. ' * 2. If the cargo has not been damaged, unloading and transport to' storage may proceed normally. Asbestos fiber in undamaged plastic, paper or lined jute bags does not present an exposure problem. Asbestos fiber bags shall be handled and stored in a manner that \7iil protect them from any damage that could create an exposure problem. `' 3. If visual inspection of cargo reveals bag damage or . loose fiber, unloading will not.proceed until pre cautions have been taken to minimize worker exposure. <' Any loose fiber in the unloading or storage area shall be removed by vacuum cleaning or other suit ; able methods and disposed of in sealed plastic bags or other closed containers. Damaged bags shall be repaired by taping or by inserting into slip bags. These remedies shall be* made before transport of the bag to storage or'use point. Approved respiratory protective equipment shall be employed by the worker - during this clean-up and unloading operation. * 8005 1280 PRODUCED BY FORD APPENDIX 4 Document No.l INTRODUCTION OP ASBESTOS PIBER INTO MANUFACTURING PROCESSES 1. Production operations involving asbestos fiber require that fiber be introduced into.the process under dust controlled conditions generally achieved by a dust collection system. .. 2. In those operations v:here bagged asbestos fiber is . being used, the fiber bags shall arrive at the work station in clean condition, free of loose fiber on . the bag surface. If the bags are stacked on pallets, the pallets must be clean and. free' of loose fiber. 3. In operations where the fiber and its container can ' be introduced directly into the process without open ' ing the container and removing the contents, dust ' . control can be achieved without a dust collection system. . 4. Asbestos fiber in the form of compressed block or extruded pellets is virtually dust free ana generally can be introduced into a process without need for a dust collection sysuem. 5. In most operations where fiber bogs ore opened and contents removed prior to introduction.into a process, ' the bag opening station must be equipped with a dust collection system. There may be production operations that do not require a 'dust collection system to achieve controlled conditions. This can be determined by dust level monitoringf A typical fiber bag opening station, with provisions for dust collection, is shown . on page of ANSI 29.5 - 1974, "Fundamentals Governing the Design and Operation of Local Exhaust Systems for the Control of Asbestos- Containing Dusts." * 6. Empty bags containing visible residues of fiber shall be placed in closed containers or scaled plastic bags for transport to a disposal site. Empty bags may be placed in closed containers ahd introduced into a man ufacturing operation. Other suitable disposal methods that do not create airborne concentrations in excess of allowable exposure limits may. be used. 44 .' 7. Fiber spills shall be removed*as often as necessary by vacuum cleaning or other suitable methods that do not create airborne concentrations in. excess of allowable exposure iimies. .. * Vv 8005 1281 PRODUCED BY FORD APPENDIX 4 Docunenc No.16 ASBESTOS DUST AND SCRAP REMOVAL AND DISPOSAL 1. Dust and friable scrap material* shall be handled by methods that do not generate airborne concentrations .' of asbestos fiber in excess of allowable exposure ` limits. If such procedures are not available, exposed employees shall wear approved respirators. . 2'. Friable scrap material for disposal shall be loaded . into closed containers or sealed plastic bags for transport to the disposal site. 3. Empty bags containing visible residues of asbestos fiber shall be disposed of in accordance with ANSI . Standard 29.5 - 1974, "Fundamentals Governing the . Design and Operation of Local Exhaust Systems for the . Control of Asbestos-Containing Dusts" or other suit able procedures. .' C, Dust which contains asbestos fibers from collection systems, such as fabric filter baghouses, must either be returned to the process, transported to a wa&Le disposal site in closed containers or sealed plastic bags, or, prior to disposal, converted to dust-free pellets or sludge. .. * Friable scrap material is defined as any scrap material that may produce, during the disposal ' operation, airborne concentrations of asbestos fibers in excess of the allowable exposure limits. i . . . * 8005 1282 PRODUCED BY FORD APPENDIX 4 Document No.19 HOUSEKEEPING IN THE ASBESTOS INDUSTRY In plants where asbestos fiber is used, fiber-containing dust shall not be allowed to Accumulate on machinery or on the floor, walls, ceiling and structural members of a building to the extent that dust dislodgement could create airborne concentrations in excess of allowable exposure limits. Equipment and buildings must be cleaned as frequently as necessary to meet this requirement. Vacuum cleaning shall be used wherever possible. Other cleaning methods, including wet sweeping, may be em ployed if usage does not generate airborne concentra tions in excess of allowable exposure limits. If it is not possible to remove dust accumulations by vacuum cleaning or other methods, compressed air cleaning may be employed. During compressed air clean ing, only personnel performing tb* cleaning opera*-, ionr. shall be present in the area. Such personnel must wear approved respirators. This operation must be foliov/ed by thorough vacuum cleaning or other suitable procedure to remove dust dislodged during the compressed air cleaning. . . :. 4 # 1 , - # / , . . , * , ' 8005 1283 PRODUCED BY FORD AMERICAN NATIONAL STANDARD APPENDIX 5 Document No.20 FUNDAMENTALS GOVERNING t . . ' TK3 DESIGN AND OPERATION OF ,, *. ` - LOCAL EXHAUST SYSTEMS FOR THE CONTROL 0? ASBESTOS-CONTAINING DUSTS \ \ DRAFT 02 - 5/2/74 8005 1284 PRODUCED BY FORD AMERICAN NATIONAL STANDARD FUNDAMENTALS' GOVERNING TEE DESIGN AND OPERATION OF LOCAL EXHAUST SYSTEMS FOR THE CONTROL 0? . ASBESTOS-CONTAINING DUSTS * 1. SCOPE ' 2.1 This standard comprises the fundamentals of good practice in industrial.exhaust systems installed to prevent unsafe environmental conditions when engaged in mining and milling / of asbestos, and the manufacture, fabrication or installation of asbestos containing products. ' 1.2 The scope of these fundamentals is restricted to normal and typical practice. . 1.3 Many of the fundamentals utilized in the design of these systems are set forth in American National Standard 25.2 - 1971, entitled "Fundamentals Governing the Design and Operation of Local Exhaust Systems". .This standard will set forth % the fundamentals and specifics related to control of asbestos-containing dusts. Fundamentals not covered will be found in ANSI 29.2 - 1971, and so referenced. 2. DEFINITIONS 2.1 Dusts. Solid particles containing asbestos riser. 2.2 Safe Level. Airborne concentrations in the workplace air not to exceed the levels specified by OSNA in the Federal Register, Volume 37, tllO of Wednesday, June 7, 1972. (5 fibers longer uhan 5 microns - per cubic centimeter, o /.our uime--werg.vcec. av.<rugt, or *j floors -- unsn 5 8005 1285 PRODUCED BY FORD -'2 2.2 Safo Level (Con'd.) microns - per cubic centimeter, ceiling value.) 2.3 Additional Definitions For further pertinent definitions, including those of: Control Veolcitv Exhaust Rates ` Exhaust Hood Branch__ Main ' ` Exhauster Air Cleaning Druipnent see ANSI ZS.2,1571., Para. 2, page 7. 3. PLAN? CONSTRUCTION AND LAYOUT 3.1 Purpose. Consideration of plant layout and construction shall include exhaust ventilation requirements for the purpose of incorporating such requirements in an over-all plan resulting in the optimum combination of capital investment and operating economy for all factors within the control of the designer. Layout based o..lj on production or aaterials-handling consider ations per se r.ay prove uneconomic when necessary exhaust or ventilation requirements are superimposed upon a layout not originally including such considerations. 3.2 Secreoation cf H&sardcus Operations. These operations should be segregated from nonhazerdous work so far as practicable. In plants where most of the processes produce harmful concen- ' 8005 1286 PRODUCED BY FORD 3.2 Segregation of Hazardous Operations. (Con'd.) trations of air contaminants, it is preferable to isolate the safe operations in a separate building or room. . 3.3 Walls and Floors. Walls and floors `should be constructed so as to permit easy cleaning and draining. Horizontal surfaces and ledges on which dust may collect should be kept to a minimum. 3.4 Plant Layout. 3.4.1 Location of Processes. Processes to be exhausted by a l single system should be located close together and arranged, if conditions permit, in order that: (1) The shortest lengths of pipe and minimum number of bends may be used in the system' (2) Proper proportioning of air flow from the various hoods may be facilitated. 3.4.2 Location of Scuicment. Equipment to be provided with local exhaust ana the components of an exhaust system should be arranged to permit the location of exhaust piping so as to: (1) Permit the free operation of cranes, elevators, trucks, etc. (2) Allow ready accessibility to the piping for inspection, cleaning, and repairs (3) Provide maximum protection of piping from damage from the outside. 8005 1287 PRODUCED BY FORD . -- /<' 3.4 Plant Layout (Con'd) 3.4.3 Separate Systems. vrhere processes generate different dusts, furr.es, or vapors which could, if intermixed, re sult in a health or an explosion hazard or corrosion, such contaminants shall be exhausted by separate systems so as to eliminate these possibilities. 3.4.4 Isolated Processes. Scattered processes or equipment operated infrequently should be provided with separate exhaust sysuems. ,. j.-hs ^; *- - -- c, 3u.idjLr.g cesrgn shou.c. juaxe possible uhe li ocation cf this ec* ui *pment so as tor ;i: Permit safe and ready access iZ) Permiu easy removal of dusu or other collected maueria.. viuhout creating a nuisance or health hazard. (3) Allow for cleaning and repairing the apparatus without conuaminatir.5.the general plant air. 3.5 '/.s'.-: Xaka-Uu Air Systems. Provision should he made for the entrance of clean, tempered air into the building to replace air removed by ex', oust systems, the minimum volume flow of such make-up air should he equal to the exhaust volume. A more suursfactory in-plant environment can be provided if the supply air exceeds the exhaust. Common practice is to increase the supply air 10 percent above the exhausu volume. A moro accurate meahod of determining the supply volume is uo increase the -apply ah eve :.ho cxhav.-c by a volume equal to the inf iltratior PQ8005 1288 PRODUCED BY FORD - -5 - /v* 1.5 New Make-Uo Air Systems (Con'd) . -*cte so determined from standard heat loss calculations. (rhis will eliminate the necessity to include the infiltration in the building heat loss calculations.) An exception to this is . a situation where it is desirable to maintain the space under a slight negative pressure. ' For additional information on make-up air systems, refer to ANSI Z9.2, 1971, paragraph 3.6, page 9. . v.l ? rooss. %. t*Ovi/S .. It is the purpose of exhaust hoods to enclose, as effectively as practical, the points where the contaminant is released, cr to create air flow through the rone or zones or contaminant release of such magnitude and direction as to carry the contaminated air into the exhaust system. Exhaust hoods and enclosures may also serve the important function of keeping materials ir. process by preventing their dispersion. h.2 Production and Dispersion of Contaminants. Distinction should be made between the production of a conuaminar.t and its dis persion. Contaminants are often produced without contamination of the atmosphere; on the other hand, dusts are frequently dis persed from areas where they are not produced. C.3 ICinetic Ir.errv cf Atmospheric Contaminants. Vhe method by which articulate contaminants become airborne determines the kur.etnc energy -eve-. PQ8005 1289 PRODUCED BY FORD - 6- , /' ' C.3 Kir.ttic Energy of Atmospheric Contaminants (Con'd) KE - h :cv2 where l\Z *= kinetic energy i'i 13 n&5S V *= velocity Contaminants have low kinetic energy when they have small mass or are released with low velocity. . 1 4.4 Sls-aerrsion of atmospheric Contaminants. Atmospheric contaminants are dispersed in one or both of two ways: v. v. 1 Cisicrr: ~r. Kinetic Energy. Particulate contaminants are projected into the air by the kinetic energy imparted to them at the time of their production or applied later by the process. Such contaminants travel through the air ur.tr'. therr kinetic energy is dissipated in over coming air resistance. The distance traveled depends primarily upon the mabs. Since particles of hygienic significance (usually 10 microns and less) (molecular state) have very small mask, their dispersion by kinetic energy is very limited, tbt instance, a 10-micron particle lading an initial Velocity of 10,000 feet per minute will have dissipated its energy after having traveled about 1.5 inches. A 2-millimeter particle having the same initial velocity will travel about 140 feet through seill air before its energy has been dissipated. 8005 1290 PRODUCED BY FORD <4.2 Dicperslon by Mr Currents. Particles of hygienic sig nificance are usually dispersed by air currents. .4.5 Typos....of.Air Motion. Stray-or secondary air motion around in dustrial processes and operations may be classified into four major types: (1) Notion or energy fundamental' to the machine or process (viz, fan action of a rotating wheel, escape of air from con ' tainers as they are filled, convection currents and air expan sion' over heated surfaces) (2) Forces incidental to the operation of the machine or process (viz, air escaping past worn pistons in pneumatic tools I or from badly placed exhaust ports, and vibration of machinery) (3) Prag of air by large particles dynamically projected from their source (viz, large particles dispersed from a surfacing machine carrying fine particles in their wake) (4) External forces (viz, air motion created by nearby mach inery operation and by workers; natural convection currents caused by temperature .changes; and air currents from nearby doors or windows, fans or heaters) 41-6 Control of Air Motion. The primary purpose of an exhaust hood is to confine or capture contaminated air, or both, rather than to remove the contaminating material from the air. To prevent the dispersion of atmospheric impurities, it is necessary to eliminate or reduce stray or secondary air currents and to develop primary or control air currents of the proper magnitude and direction about the zone of dispersion. Before the actual design of an exhaust hood is undertaken it is essential for . 8005 1291 PRODUCED BY FORD 4.6 Control of Air Motion (Con'd) economic reasons to eliminate or reduce the effects of dispersing air currents by direct, nonventilation means. Any such mechanical improvements must be permanent in nature lest their subsequent alteration or removal render the exhaust system inadequate. These preliminary measures include:, ' (1) Altering the design or operation of the process, as for example, in changing the location .of the compressed air exhaust on *. pneumatic tool. (2) Deflecting or eliminating external air currents, as from nearby moving machinery, open windows, space heaters, or air- supply grilles. (3) Preventing the machine from creating undesirable air currents by the use of suitable baffles or enclosures, so as to (a) Utilize t;e motion of the machine to produce air currents toward the proposed exhaust hood, or (b) Prevent the development of adverse extraneous air motion by the machine;(such as the fan action of a grinding wheel). (41 Installing the hood so that it transects the path of dynamically pi ported particles. If this is not desirable, as in materials-handling systems, baffles should be installed to destroy the motio.n of coarse particles and, with it, the air drag which causes the dispersion of minute particles. (5) Restricting the free entry of air at the point of material entry on operations (such as hopper filling) where ambient air i6 entrained with the materials being processed. Dispersion 8005 1292 PRODUCED BY FORD 4.6 Control of Air Motion (Con'd) of contaminant-laden air by the "fan action" of the moving material thus may be reduced. t (6) Eliminating unnecessary vibration of machinery. These measures will not ordinarily eliminate the need for exhaust 4 ventilation but are of great practical value in reducing the required size and capacity of the exhaust system. 4.7 Hood Design. The primary objective of hood design is^ to confine or capture the contaminant effectively with a minimum rate of air flow into the hood. The important factors are the air velo city in the area of contaminant dispersion, the area or volume of the dispersing mechanism and the volume rate of air exhausted. The air velocity toward the hood must be great enough to counter act the opposing velocity of the contaminated air and the in fluence of stray or secondary air currents. The rate of air exhausted must be such as to capture enough of the contaminant to maintain in the breathing zone of nearby workers a safe level of whatever contaminant remains. 4.8 Determination of Required Air Velocity. The air velocity which must be developed by the exhaust hood at the point or in the area of desired control is based on the magnitude and direction of the air motion to be overcome end is not subject to direct and exact evaluation. 8005 1293 PRODUCED BY FORD 4.9 Air Volume Requirements for Exhaust Hoods. Exhaust hoods should be so designed and located sb to provide the necessary air velocity with the lowest possible air flow. The following general rules should be observed: 4.9.1 Enclosure of Process. The process should be enclosed ' as much as possible (see Fig. 1).* The practical nec- essities of operating the process must, of course, be taken into account. Too complete enclosure of a process may result in economic penalties in terms of operating efficiency, or capital expenditure greater than that for the larger exhaust system required by a less complete enclosure; an economic balance should be maintained between the two extremes. The quantity of air required for enc3'.',;ir.v or partially-enclosing hoods is determined by two factors: (1) The air velocity through all openings must be great enough to prevent the escape of contaminated air, and the air volume must be sufficient to carry away all air or gas introduced into or created within the enclosure. In the f^si^n of the hood, special attention must be paid to the fit around rotating shafts, etc. and to the sel ection of air volume so that there will be an adequate flow of air into the hood at these points. (2) The velocity within the enclosure should be high enough to remove the contaminant from the hood, except that the velocity should not be high enough to carry away *ANSX Standard Z9.2 1971, page 14 8005 1294 PRODUCED BY FORD 'll 4.9 Air Volume Requirements for Exhaust Hoods (Cont'd.) 4.9.1 Enclosure of Process (Cont'd.) . valuable products unless these are recovered later. i In some applications the velo* city in the enclosure need not be high enough to prevent.settling; in this case, provision should be made for the 'easy removal of settled dust. When settling is not permitted, the air inlet location and exhaust nozzle connection are important design factors. In general, enclosing hoods should not also enclose the worker, the worker will usually require extensive personal protective equipment, as for example in totally enclosed sand-blast rooms. , 4.9.2 Location of Nonrenclosinq Hoods. Exhaust hoods that do not enclose the process should be located as close as possible to the point of contaminant dispersal and should provide air flow in the direction from the worker to the contaminant source (see Figs. 2 and 3).* Air velocity created by the exhaust hood, for all but long slot-type hoods, varies approximately inversely with the square of the distancefrom the hood opening. For long-slot type hoods, it varies inversely with distance. ANSI Standard Z9.2 1971, pp. 15 and 16 8005 1295 PRODUCED BY FORD 12- 4.9.3 Utilization of Air Currents. The hood or part of it should be located so as to utilize the directional tendency of the notion of the contaminated air for its own capture (see Fig. 4).* In some cases, however, the hood opening must be normal to the directional tendency in the motion of the contaminated air, or remote from the main contaminant'concentration, in order to reduce the amount of material picked up. 4.9.4 Baffles and Flanges. Baffles for minimizing cross drafts, and hood flanges for increasing hood efficiennier . are important elements to be considered in hood design. 4.10 Calculations of Airflow. For detailed information on the calculation of air flow through hoods refer to ANSI 29.2-1971, paragraph 4.10, page 14. *ANS1 Standard 29.2 1971, page 17 8005 1296 PRODUCED BY FORD 4,11 Specific Hood Designs. Some special considerations for asbestos processingi 4.11.1 Transfer Points cotJiseyoR -COVER BEITS BTU>EN 7RANECR POINTS Fig. A , COAf\JYO$ BELT EMCLOSU/YE 8005 1297 PRODUCED BY FORD 4.11.2 Asbestos Tiber Bng Opening Stations PRODUCED BY FORD . - is 00 4.11 Specific Hood Designs (Cont'd) .` ' t- 4.11.2 Asbestos Tiber Bag Opening Stations (Cont'd) These operations should be enclosed that there i6 an exhaust air interface between the operator and the du6t producing - operation. The bag must be opened completely under a . ventilated hood and disposed of under ventilation, per Fig. B , (see para. 4.11.4 for notes on bag disposal.) I 4 1?..3 Non-Enclosing Hoods. Thi6 type of hood should be avoided and only used as a last resort after determining that enclosing the process i6 impossible. When necessary to use this type of hood, flanges and skirtB are necessary. Without them excessive volumes of air will be required to effectively control dust at any distance from the hood face. 4.11.4 Empty Bag Disposal. The handling of empty, asbestos bags generally' produces significant quantities of fine asbestos dust. Empty bags must be disposed of in a controlled manner. Following are some methods , i to accomplish this* 8005 12** PRODUCED BY FORD -16- 4.11 Specific Hood Designs (Cont'd.) 4.11.4 Empty Bag Disposal (Cont'd.) ' (1) Bag disposal into a clean bag in conjunction . with a ventilated bag opening station. (See fig. 2, pg 14) (2) Pneumatic disposal of .the bags to a trap, with the exhaust air^going on to a cloth bag-type dust collector. The collected empty asbestos bags can then be fed by gravity intj a clean container or baler, . for disposal. (3) Shredding of the paper bags and removal pneumatically, as above, or by slurry method, or re-fed into a wet process that utilizes paper. (4). Automatic bag opening and bag disposal equipment used in conjunction with baler or pneumatic conveying, ** is available. . Manufacturers of bag opening devices that claim the ability to open pressure packed asbestos fiber bags are: Fairmont Engineering 216 Stiger St. Hackettstown, N.J. Taunton Engineering Company 700 West Water St. Taunton, Mass. 02780 Stuart Glapat Corp. 1639 Moxahala Ave. Zanesville, Ohio 43701 . 8005 1300 PRODUCED BY FORD - 17 ; 5. EXHAUST DUCTS * 5.1 Purpose. The purpose of the exhaust duct work is to control the ' flow of air, in the desired quantities and at the desired velo cities, from each exhaust hood to the point of discharge. 5.2 Duct Systems. , * 5.2.1 For general consideration refer to ANSI 29.2-1961, para. 5.2, page 17. ,* . 5.3 Conveying and Design Velocities. * 5.3.1 A distinction is made between "transport velocity" ("conveying velocity") and "design velocity" for dusts. Transport velocity is the minimum velocity required to keep the dust moving through the duct. Design velocity is generally higher than transport velocity for the following reasons t (1) To provide a factor of safety to insure the main tenance of transport velocity in the main in the event of closure of one or more branches, leakage of duct work, corrosion or erosion.*of the fan wheel, increase in system resistance due to denting of duct work, and other causes (2) To balance systems having a number of branches (3) To allow the use of smaller 6ize ducts. 5.3.2 Recommended minimum air velocities. ....Duct risers - 4100 fpm Horizontal ducts - 39.00 fpm . i` .. . . 8005 1301 PRODUCED BY FORD 5.4 Air distribution I For detailed information on air distribution,'and methods of , . air balancing, refer to ANSI 29.2-1971, paragraph 5.4, page 20. 5.5 Duct design data. _ For detailed data on duct, design, refer to ANSI 29.2-1971, paragragi 5.5, 5.6, 5.7 and 5.8} pages 22 through 37. 5.6 Special design considerations. ' ii . 5.6.1 Ducts must be designed for abrasive service. (1) Milling: Rock Line - 12 Ga. - All sizes . Fiber Line - 14 Ga. - All sizes Dust Control - 16 Ga. - up to 30" and 14 Ga. - over 30" ' -(2)Fiber Handling: Conveying - 14 Ga. - All sizes Dust Control - 18 Ga. - 5" to 12" . 16 Ga. - 13" to 30" *t < ' 14 Ga. - over 30" Fittings - 2 guages heavier - all sizes (3) `'i'ecial cases (especially rock handling) - ex perience may show that some areas will require special extra heavy design, such as "wear-back" elbows and wear plates on fittings. 8005 1302 PRODUCED BY FORD 19 6. AIR CLEANING EQUIPMENT .1 Definition. Air cleaning means the separation of contaminant ' from the air handled by ventilating systems. The term "air ' .cleaning" as used in this standard i6 restricted to the sep aration of contaminants from the air handled by local exhaust systems. .' . 6.2 Purpose. Air cleaning is required for 'one or more of the following reasons: (1) To prevent the creation of a hazard or nuisance in the area exposed to the discharge of the local exhaust system. (2) To prevent recontamiriation of the plant air from the di3charge air. (3) To protect fans or other air-moving equipment. (4) To permit recirculation of the exhausted air, under certain circumstances, in order to reduce heating or cooling losses from the plant. ' (5) To recover valuable materials that may be present in the exhausted air. 6.3 Pollution. 6.3.1 Air cleaning equipment is required in exhaust systems handling asbestos fibers. 6.3.2 Local legal requirements may be more stringent than Indicated by the above factors. Such requirements are usually a matter of public policy and are concerned with a general or area-wide pollution problem not attributed to any specific or single source. 8005 1303 PRODUCED BY FORD - 20 - 6*4 Characteristics of Air Cleaning Equipment. The perfect air cleaner does not exist; equipment selected should possess a6 many as possible of the following characteristics: 6.4.1 Degree of Cleaning. The concentration and mass rote of emission of the contaminant in the cleaned air shall be sufficiently lpw that neither hazard nor nuisance is created inside or outside the plant. I 6.4.2 Legal Reguirements. The concentration and mass rate of emission of contaminant in the cleaned air should be below that specified by existing state or local codes, or below that which might reasonably be anticipated in future codec. 6.4.3 Uniformity of Performance. Emission rate, capacity, and . resistance of the air cleaner should remain relatively constant throughout its daily operating cycle and be nearly independent of entering dust concentration. * 6.4.4 Maintenance and Cleaning. The routine maintenance and cleaning of the air-cleaning plant should not interfere , ' with normal operation. . 6.4.5 Re-use or Disposal of Collected Material. Collected material should be in such form or condition a6 to facili tate safe disposal or economic re-use. 6.4.6 Resistance. The pressure drop 6hould be as low as is con sistent with other characteristics desired. .< 8005 1304 PRODUCED BY FORD 216.4 Characteristics of Air Cleaning Equipment (Cont'd.) 6.4.7 Construction. Equipment should be compact, ruggedly constructed, easily inspected and maintained. Important faqtors in construction considerations are abrasion, ' corrosion and temperature. 6.5 Types of Air Cleaners. Many types of air cleaners are available and are discussed thoroughly in the literature. The first recommendation of the Federal Environmental Protection Agency , for asbestos dust collection is a fabric bag filter. The Federal I Environmental Protection Agency recommends an alternate for use in certain circumstances as stated in Paragraph 6.5.3. } The Federal Environmental Protection Agency will accept air cleaning devices if they are proved as effective as their baBic recommendations. (See Appendix A) 6.5.1 Fabric Bao Filter - Mechanical Shake. This type of collector is better than 99% efficient in collecting asbestos containin dusts when properly sized, operated and maintained. It should have following specifications: % (1) Mechanical Shaker type with air/cloth ratios of 2.0:1 to 2.5:1. (2) Cloth cotton sateen bags, silicone-treated. (3) Cloth permeability - See Appendix A. . (4) Cloth weight approximately 9.6 oz./sq. yd? count 96 x 60. (5) Heavy duty shaking mechanism. (6) Hoppers to have 60 minimum slope and their inside surfaces to be smooth and free of weld spatter. (7) Minimum discharge gate opening of 12'' x 12" to ' minimize fiber hang-up in the hopper. (6) Solid-state timer to automatically 6hake the bags on fan shut-down. 8005 1305 PRODUCED BY FORD -22 6.5 Types of Air Cleaners (Cont'd.) 6.5.1 Fabric Bag Filter (Cont'd.) (9) Manometer for continuous observation of operating condition of cloth bags. Additional preferred features might include: , (10) Continuous-duty type (compartmentized) designed to allow cleaning or maintenance without reduction of dust control ' on the production system. Provide close-fitting dampers for positive isolation of each compartment while shaking. (11) Minimum 12" x 12" rotary valves on the hopper discharge to allow continuous disposal of collected asbestos dust to avoid material hang-up in hoppers. It would be advantage >us to have an air tight slide valve above the rotary valve to seal the hopper during maintenance of the rotary valve. (12) Trough hoppers with min. 9" screw conveyors and 12" r*otary valve*s for'most trouble-free disposal of fibrous dust;. (13) Means of access to compartments while operating for maintenance purposes. (14) Cloth envelope collectors should be avoided due to excessive bridging of fibrous dust between the envelope. (15) Inspection ports and internal lighting. 6.5.2 Fabric bag filter - reverse jet type. Reverse jet types Reverse flow types of collectors with air/cloth ratios of the order of 6:1 and felt tubes and utilizing compressed 8005 1306 PRODUCED BY FORD -23 .5 Types of Air Cleaners (Cont'd.) 6.5.2 Fabric bag filter - reverse jet type (Cont'd.) air jets or an auxiliary fan for reversing air flow . through' the tubes for cleaning purposes can be used successfully on fibrous dust. They require less space than mechanical shake collectors operating at lower air/cloth ratios. However/ they are not recommended * for asbestos due to the maintenance disadvantage of requiring work and handling of asbestos covered bags on the dirty air side. Where space considerations outweigh the inherent maintenance ' disadvantages connected with the reverse flow type collectors/ and such units are installed on applications involving asbestos-containing dust/ the following precautions are recommended: (1) Maintenance personnel entering such collectors for tube inspection, repair, or replacement shall be protected by means of approved respirators and protective clothing. . (2) Precautions shall be taken to prevent escape of asbestos-containing dust from collector access ' openings during inspection and maintenance procedures, and any spillage of 6uch dust shall be cleaned up immediately by vacuum system or by wet sweeping. (3) On applications involving collection of bulky fibrous waste materials, care should be taken in selecting 8005 1307 PRODUCED BY FORD -24- 6*5 Types of Air Cleaners (Cont'd.) 6.5.2 Fabric bag fAIter - reverse jet type (Cont'd.) (3) (Cont'd.) collectors to make certain sufficient clearance ecists between tubes to preclude possibility of bridging of accumulated material in the space between tubes. This may require special spacing of tube centers in the tube sheet or the use of smaller diameter tubes than are normally supplied in this type of collector. (4) Only clean dry compressed air is supplied to cleaning nozzles. , 6.5.3 Other Collectors. A federal Environmental Protection Agency recommended alternate to a fabric bag filter is a high energy wet scrubber (See Appendix A). However, it is recommended only .under the following operating conditions: ' * (1) Fire or explosion hazard 1 (2) Where moisture content of the exhaust air would create condensation in a dry collector with resultant operating and maintenance problems. The cleaned air from this type of collector should not be recirculated into the plant. 6.6 Pre-Cleaners. When exceptionally heavy dust loadings are encountered, (over 10 grains/cu. ft. of air) pre-cleaning of the air stream should be done to reduce wear on the cloth 8005 1308 PRODUCED BY FORD ' -25 6,6 Pre-Cleaners (Cont'd.) . 6,6.1 ' Settling Chanber. A large chamber with relatively low velocities (and sometimes a rapid change in direction) to utilize gravitational settling. Simplest arrangement is an inlet plenum on the end of the fabric bag filter so collected dust falls into the collector hoppers, eliminating the requirement for additional dust disposal facilities. .* 6.6.2 Inertial Traps. Similar to above but utilize specifically designed direction changes to add inertial settling to gravitational forces. 6.6.3 Cyclones. For higher efficiency pre-cleaning, especially in process work, a specifically designed, high efficiency (by weight) mechanical type of du6t collector should precede the cloth collector. The cyclone is the simplest and most economical device for thi6 purpose. 6.6.3.1' For derailed information on design of cyclones, refer to ANSI Z9.2-1971, paragraph 6.8, page 38. 6.7 . Field Testing. Reputable manufacturers of proprietary air-cleaning equipment are often able to offer guarantees of performance of their equipment based on experience or on pilot installations with the materials or operations in question. Laboratory tests are often unreliable because of the inability to duplicate all field conditions, such as the degree of dispersion of the contaminant, electrostatic charges on particles, variations in loadino. etc. Therefore, especially where a process or material 8005 1309 PRODUCED BY FORD 6.7 Field Testing (Cont'd.; 1b new, a pilot installation should be made and studied at the process site.' Since the questions of maintenance of edeguate collection efficiency and performance, wear on equipment, etc., are more important than operating characteristics when the material or process is new, the pilot installation should be operated and studied over a long enough time period (sometimes a year or more) to permit accurate 'conclusions. The test data should include measurements of the contaminant loading in both dirty and clean air streams, preferably over a wide range in a variation of factors (such as water rate and air flow rate) which may substantially affect the collecting efficiency. All measurements of contaminant concentration should be performed by standard methods and techniques. 7. EXHAUSTERS 7.1 Definition _* 7.1.1 The term "exhauster) as used herein refers to any device which may be used to create the required flow of air in a local exhaust system. 7.1.2 An exhauster may be any one of the following! (1) Fan (2) Turbo-compressor (3) Positive displacement blower (4) Ejector 7.2 Fans. A fan is the only type of exhauster suitable for the local exhaust systems described in this standard. The accepted 8005 1310 PRODUCED BY FORD 27 7.2 Fans (Cont'd.). those of the Air Moving and Contltioning Association, Inc. Fans are usually of two main types, centrifugal or axial. In a centrifugal fan the outlet is in a plane normal to the inlet. In the axial fan, the air leaves in the same direction that it enetered. (See Fig. 21.) . 7.2.1 Centrifugal Fans. A centrifugal fan consists of a fan ` rotor or wheel within a scroll-shaped housing, and includes driving-mechanism supports either for belt drive or direct connection. Centrifugal fans are classified according to the type of rotor blade used. The main types of centrifugal fan wheels are forward curved, radial blade or paddle type, and . . the backward curved blade. Combinations of these three basic types can and have been made. Centrifugal fans are also classified according to the rigidity of construction. 7.2.1.1 For use with the fabric bag filter collectors recommended t herein a centrifugal exhauster with a radial or backward ' curved wheel is recommended. For detailed description of these units, refer to ANSI 29.2-1971, para. 7.2.1, page 4 7.3 Fan installation. . 7.3.1 The exhauster preferably should be installed on the clean-air side of the collector for the following advnatages: (1) Wear is a minimum since it does not handle abrasive dust. (2) It can be a high-efficiency, backward-curved blade 8005 1311 PRODUCED BY FORD -28 7.3 Fan installation (Cont'd.) 7.3.1 (Cont'd.) > type, when volume and pressure indicate a significant saving of horsepower. (3) Any air leaks in the system and dust collector housing will be inward, preventing dust blowing out into the area. (4) Any dust leak, such as a,broken bag, will be limited to the fan discharge stack. The stack should be readily visible so exhaust stream character can be used as a signal that maintenance is required. However, there are instances where it may be preferable to locate -he fan between the dust source and the collector. . In a positive pressure installation of this type, the dust from fan to collector should be kept as short as possible and be completely air tight. Such instances might be . (1) Eliminate potential water leakage problems associated with the collectors installed outdoors. (2) Permit minor servicing while unit is in operation. 7.3.2 A discharge evasee (expansion cone) should be used where required to reduce air velocity to about 3,000 fpm for maximum static pressure regain, maximum efficiency and minimum stack loss. 8. CONSTRUCTION AND INSTALLATION 8005 1312 PRODUCED BY FORD -29 9. OPERATION AND MAINTENANCE 10. CHECKING OPERATION OP LOCAL EXHAUST SYSTEMS Por recommendations on 8., 9, and 10 above, refer to ANSI STandard 29.2-1971 i 8005 1313 PRODUCED BY FORD