Document ymX16VMBNvrna2ejD4JOXOR7r

Shell Oil Company Inleroftlce Memorandum FEBRUARY 6, 1984 U Ijf ru^.' /I I I R'ji'jrn Dccurrirn''.Drllo I PLAINTIFF'S EXHIBIT Record Copy i.i File lr.fo;'rrr:i:ri Copy SH-3538 FROM: Record copy in Satellite ^a. 'RXt-^Q<60 rO (4. L-Lec MANAGER, HEALTH & SAFETY, MANUFACTURING & TECHNICAL, U56.HXie. HEAD OFFICE * Px.L-^6cthli i ep TO: MANUFACTURING LOCATION MANAGERS ANACORTES NORCO DEER PARK ODESSA EL PASO TAFT GEISMAR WILMINGTON MARIETTA WOODBURY MARTINEZ WOOD RIVER MOBILE SUBJECT: HS&E GUIDELINES FOR APPLICATION AND REMOVAL OF LEAD/CHROMATE-BASED COATINGS The attached HS&E guidelines for Application and Removal of Lead/Chromate-Based Coatings has been approved by Manufacturing senior management and is being distributed to you for implementation. For reference, an HS&E guideline is: "An indication or outline of appropriate internal actions to be taken throughout Shell relative to a particular subject. Those responsible for specific actions are expected to exercise judgment in use of the guidelines. However, selection of options within the guidelines and extent to which the guidelines are followed must be with the intent of achieving comparable results to those anticipated by the guidelines. HS&E Guidelines must be: 1) approved by the Vice President HS&E and the vice presidents or general managers of impacted organizations; 2) implemented, managed and reviewed in such a manner as to achieve effective operation." While guidelines provide flexibility for implementation, there is expectation of equivalent performance. Since results are subject to confirmation by the "CompTiance Assurance Review" mechanism, we suggest that a copy be placed in your location's copies, of the Compliance Assurance Review Manuals along with distribution to those responsible for implementation. (A copy of the Compliance Assurance Review Manual distribution list is attached for reference.) ABS-003296 LAM 0315667.068 Health & Safety, Manufacturing & Technical were represented on the task force which developed these guidelines. We plan to issue equivalent information as an addendum to our Health and Safety Procedure Guidelines (number 508 -."Safe Work Practices - Maintenance - Painting"). J. S. Szymanowski KCC:PJW Attachments cc: H. L. Kusnetz R. H. Brown LAM 0315667.069 ABS-003297 GUIDELINES FOR APPLICATION/REMOVAL OF LEAD/CHROMATE-BASED COATINGS The Task Force, after studying the information and data developed during the course of the project, has put together a set of guidelines for application and removal of lead/chromate-based coatings. It is the Task Force's intent that these guidelines will offer clear direction in maintaining regulatory compliance where use of lead/chromate-based coatings is deemed necessary. The Task Force recognizes that at present, in some applications (especially in offshore installations), there are not satisfactory substitutes for lead/chromate-based coatings. Each Shell location^should review existing rules/procedures to ensure that these guidelines are incorporated. 1. Utilize lead/chromate-free coatings within the company unless significant surface protection is sacrificed by the use of such coatings. If a* particular application requires use of lead and/or chromate-containing coatings, notification of the activity should be made to the appropriate health/safety group for action as required. 2. During application/removal of lead/chromate-based coatings, NIOSH approved respiratory protection equipment should be worn by all employees involved. For abrasive-blasting, this must be a properly fitted and maintained air-supplied hood with an uncontarainated air source. For application (spray-painting), a half-face cartridge respirator for organic vapors/dust, mist and fumes is required. In addition, chemical goggles are required for eye protection. Skin contact should be minimized, and employees should remove any gross amounts of coating from the skin immediately. 3. During application/removal of lead/chromate-based coatings, initial monitoring has indicated that lead/chromate exposure limits may be exceeded up to 50 feet downwind of the job site. The potential exposure zone should be clearly marked. All non-essential personnel should remain out of the area (other than passing through) while work is in progress. If this is not feasible, appropriate NIOSH approved respiratory protection (see //2) should be provided to personnel working within the area during application/removal (see also #4). 4. If Shell employees must work in the potential exposure zone during application/removal of lead/chromate-containing coatings, industrial hygiene monitoring may be appropriate, in addition to the respiratory protection. Measured exposure levels exceeding the OSHA PEL for lead or the ACGIH TLV for water - insoluble hexavalent chromium should be reported to Corporate Medical Department. CF8403101 LAM 0315667.070 KBS'003298 2 5. Shell is responsible for informing contractors of any potential hazards (of which it is reasonably aware) associated with lead/chromate-based coatings. Contractors are expected to utilize procedures which provide appropriate protection for their employees when involved with application/removal of these coatings. Any requirements of the OSHA Lead Standard that apply to the application/ removal of lead-based coatings are the responsibility of the contractor. Upon request, Shell will supply guidance to the contractor in meeting these requirements. \ 6. Residues from abrasive-blasting of lead/chromate-based coatings should be tested for lead and/or chromium content (by the EPA leachate test or applicable state agency test) to ,, determine waste classification (if residue is to be removed from job site). This is not required in offshore work. CF8403101 LAM 0315667.071 ABS-003299 Distribution List Health and Safety Compliance Assurance Review Manual 12/82 Edition ' Operations Vice President Health and Safety - Operations - Manager Environmental Conservation - Manager Products Distribution - Operations Support - Manager. Products Distribution - Operations Support - Contract Terminals - Manager Health and Safety - Products Distribution - Manager Chemical Logistics Transportation Safety & Regulations - Manager Domestic Raw Material Supply Terminal Operations - Manager Marine - Marine Services - Manager Manufacturing Locations Deer Park Manufacturing Complex Superintendent, Health and Safety Manager, Safety - North Manager, Safety - South Manager, Employee Relations Manager, Industrial Relations Martinez Manufacturing Complex Manager, Health and Safety Manager, Employee Relations Norco Manufacturing Complex Superintendent, Health, Safety and Environment Manager, Health and Safety Manager, Employee Relations Wilmington Manufacturing Complex Manager., Safety and Industrial Hygiene Manager, Employee Relations Wood River Manufacturing Complex Manager, Safety and Industrial Hygiene Manager, Industrial Relations Manager, Personnel Anacortes Refinery Manager, Safety Manager, Employee Relations Odessa Refinery Safety Representative Manager, Services ABS-003300 El Paso Plant Safety Representative Manager, Services . Geismar PlantManager, Health, Safety and Environment Manager, Employee Relations Marietta PTant Manager, Health, Safety and Environment Manager, Employee Relations Metairie Plant Safety Representative v Manager, Employee Relations Mobile Plant Manager, Safety, Health and Environment Manager, Employee Relations Taft Plant Safety Representative Manager, Services Woodbury Plant Manager, Health, Safety and Environment Manager, Employee Relations Oil Products Distribution . Area - Managers East . . South West Midwest Sewaren Plant - Manager Willbridge Plant - Manager Exploration and Production Safety and Environmental Conservation - Manager (40) Health, Safety and Environment Vice President General.Manager Environmental Affairs - Manager Water Programs & Special Studies - Manager Plans & Support - Manager . Product Safety and Compliance - Manager Corporate Medical MedicalServices - Manager . Safety and Industrial'Hygiene - Manager (6) Information Services LAM 0315667.073 ABS-003301 77 Coo rvt9 <j 1^> u Po mT T?,SwobCiiei\%^ ?. %-ochA 1^0a<3f^^ Wjl- _______________ \ ~ S^er\ ^Jlcw^nx^ . _____________ ____________\ flJO 7~: -o /o i Lb &v^ Le/)&(^ piaz&z-^ . 71 irw kb 7o/t() ) N LAM 0315667.074 ABS-003302