Document zQ0EaVq21bqDD8zgG44bzDNOg
J. Z. NELSON R. P. CARTER
DRAFT TO
December 11, 1972
RE: REPLACEMENT OF ASBESTOS-CONTAINING INSULATION BLOCK Ref: See Attached List
On December 7, 1971, the Occupational Safety and Health Admin istration issued an emergency standard for worker exposures to asbestos fiber because of what they considered to be a serious hazard to the health of workers having asbestos exposure. On January 4, 1972 OSHA proposed a permanent standard for worker
asbestos exposures. On June 7, 1972, a permanent standard was adopted making effective July 7, 1972, the maximum time waited average exposure of five asbestos fibers having a length longer than five micrometers per millimeter of air. With this limit, to be dropped to two fibers per millimeter maximum effective July 1, 1976. This permanent standard also requires the use of engineering controls to meet these limiting exposures where such measures are technically feasible, and allows the use of
respirators only in emergencies or where such engineering control
methods are either not feasible or feasible methods have failed
to meet the required limits.
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/f One of the possible means of "engineering control" is to replace
the use of asbestos-containing materials wb-ieir products not con taining asbestos. As described in reference six, there is now available an asbestos-free type of insulation block for use in fur
tit,nace and smelting pot applications in the form of JohnJ-/*?!^,.
Superr^X-AF Grades. As soon as the supply of these grades is adequate, we will begin to use these materials for repair and re placement of furnace and pot linings and for construction of new furnaces and pots. However, until all our existing furnace and pot linings have been converted over to the use of the asbestos-free materials, we must utilize practices which will meet the requirements of the permanent exposure standard. This means that we must employ for our furnace and pot lining repair and construction operations a combination of engineering controls and where permissable, use of respirators^to comply with the provisions of the permanent standard. This will necessitate the maintaining of very adequate records of the type of block in use in each pot and furnace insulation until such time as these have all been converted to the use of the asbestos-free type block so that proper use of the required engineering controls and where permissable respirators
3. can be employed to comply with the standai'Bs. This suggests that it may be very desirable to set up some type of card or index file which will reflect the insulation block in each such unit to serve as a ready reference for the maintanence crews to determine when the required engineering controls and use of respirators required for the asbestos exposures must be used. This will require close coordination among the various groups involved at each location for performing these operations and also for monitoring worker exposures. Will each Works please advise us of the definite plans which you have made to accomplish the objective of complying with the asbestos standard during this transition period to the use of asbestos-free insulation block.
RPC/map
LIST OF ATTACHMENTS
Attachment #1 R. P. Carter's memorandum dated 12/23/71 to all Industrial
Hygienists RE: EMERGENCY STANDARD FOR EXPOSURE TO ASBESTOS DUST
Attachment #2 George H. Farrah's memorandum dated 4/17/72 to the Chairmen,
Environmental Health Steering Committees RE: INDUSTRIAL HYGIENE NEWSLETTER - ASBESTOS DUST EXPOSURES
Attachment #3 Thomas B. Bonney's memorandum dated 7/1/72 to all Industrial
Hygienists, Plant Physicians, Safety Directors RE: OSHA STANDARD FOR EXPOSURE TO ASBESTOS DUST
Attachment #4 Thomas B. Bonney's memorandum dated 7/20/72 to all Industrial
Hygienists, Safety Directors RE: APPROVED ASBESTOS RESPIRATORY PROTECTION
Attachment #5 Robert P. Carter's memorandum dated 8/21/72 to all Industrial
Hygienists RE: ASBESTOS-CONTAINING REFRACTORY AND INSULATING MATERIALS
USED"IFTUENACE-AND' 'CASTING' "EQUIPMENT CONSTRUCTION------------
Attachment #6 Pittsburgh Purchasing (Industrial Group) memorandum dated 10/4/72 RE: NATIONAL PURCHASE AGREEMENT P-615951
"JOHNS-MANVILLE SUPEREX INSULATION BLOCK