Document zdjQBRxkDEaxg1B849a4kGNja
Federal Register / Vol. 51, No. 119 / Friday, June 20, 1966 / Rules and Regulations 22677
permissible exposure limit for allowable recommended standard, OSHA has
revised standard, i.e.. "engineering
airborne concentrations of asbestos. The chosen not to adopt a product and
controls first, work practices, and then
AIA/NA argued that lowering OSHA's process categorization scheme in the
the final [choice of method] being
current PEL of 2 f/cc was not possible
Final standard for asbestos. In addition personal protective equipment" (see
because of the inherent sampling and
to the objections to such an approach
transcript of CACOSH proceedings). On
analytical Variability inherent in the use discussed earlier, OSHA notes that the other issues raised by requirements of
of the OSHA method (for a discussion of AIA/NA's recommendations are
the draft under review, CACOSH urged
the variability issue, see the Methods of intended to apply predominantly to the OSHA to reFtne particular provisions.
Measurement section in the Summary
installation of new products in the
OSHA has generally incorporated
and Explanation for General Industry
construction environment, and would
CACOSH's suggestions. For example, in
[Section X. below). As discussed in
thus not address those construction
response to the point made by Mike
detail in the Preamble section on
operations that so many commenters
Deis of Better Working Environments
Technological Feasibility (Section VII), pointed to as being the most hazardous: that respirators should be qualitatively
OSHA has determined that achieving
Asbestos renovation, demolition, and
fit tested with every wearing, OSHA has
the new PEL of 0.2 f/cc as an 8-hour
removal operations.
revised the final standard specifically to
time-weighted average is feasible in the great majority of workplaces with the
use of engineering and work practice
The Advisory Committee for , Construction Safety'and Health. At several critical junctures during the
cross-reference 29 CFR 1910.134(e). Section 1910.134(e)(5)(l) requires employers to ensure the proper Fitting of
controls alone, although respiratory
asbestos rulemaking, OSHA has had the half-mask respirators by checking the
protection may be required in some
benefit of the Advisory Committee's
facepiece fit "each time he [or she] puts
operations.
review of various draft versions of the on the respirator." In addition, CACOSH
The AIA/NA'8 recommended standard was simitar in many other
asbestos construction standard. Most recently, CACOSH reviewed a draft ,
noted several minor errors in the draft standard being reviewed, particularly in
respects to the standard recommended standard at its September 26-27,1985
the draft respiratory protection section,
by the BCTD (Ex. 330). For example, the meeting (see transcript of CACOSH
and these have subsequently been
AIA/NA's recommendations include the proceedings for that date). In addition to . corrected in the final standard (see
adoption of a product classification
providing specific reviews of successive transcript of CACOSH proceedings).
scheme that would rank asbestos-
drafts of the asbestos standard for
The final standard thus reflects, in a
containing products used in construction construction, the Committee also
large number of provisions and in many
in accordance with their potential for
developed, in 1980, a comprehensive
ways, the expert advice received by the
releasing airborne concentrations of
document entitled Report on
Agency from the Advisory Committee
asbestos. Implementation of the AIA/ NA approach would require
Occupational Health Standards for the Construction Industry lEx. 84-233).
over the course of this asbestos rulemaking.
manufacturer certifications'and the
validation of empirically determined product classifications, including the use of objective data or exposure studies
Although this document is not directed specifically to asbestos, many of its Findings apply to the revised construction standard. For example,
X. Summary hnd Explanation of the Revised Standard for General Industry
1. Paragraph (a). Scope and
conducted by fully qualified testing
CACOSH expressed concern about the application..
laboratories and empirical Geld testing -difficulty of applying many traditional
Like the existing asbestos standard
by OSHA inspectors and.others to
health standards requirements in the
and other OSHA health standards such
confirm these test results.'
construction setting; specifically, the
as inorganic arsenic (11910.1018); lead
According to the AIA/NA, examples . Committee noted that medical
( 1910.1025), DBCP (; 1910.1044). and
of products qualifying.for Category A
surveillance, the use of engineering
acrylonitrile (8 1910.1045), this revised
status (the least hazardous grouping)
controls, and extensive recordkeeping standard applies to all "occupational
include products in which asbestos
. often pose problems in this high-
exposures to (asbestos)." OSHA has not
fibers are bound, coated, or enclosed by tumover, out-of-doors, short-term work defined the term "occupational -
other materials, such as mastics,
environment (Ex.-84-233). .
exposure" in the regulatory text.
mechanical packings, oil seals', compressed gaskets, sealants and
In the context of OSHA's revised asbestos standard for construction, the
However, because of increased public awareness pf the hazards of asbestos
caulks, roof coatings, and electrical insulating paper. (Ex. 84-307, p. 23). Category B.products would include
Committe voted overwhelmingly in favor of the issuance of a separate standard for the construction industry .
and its ubiquitousness, inquiries have been made to OSHA concerning the applicability of the standard to
' those certified by their manufacturers as (Ex. 84-424). CACOSH also
being incapable, under reasonably
recommended that the PEL for
foreseeable conditions of processing or construction be set at "the lowest
exposures in buildings which may not result from manufacturing, processing or installing asbestos products. Significant
use, of releasing asbestos fibers in excess of the PEL "when one or wore
feasible level" (Ex. 84t424, pp. 11-13), as areas of concern expressed were
OSHA has in fact done (see the
exposures to office employees in .
specified Fabrication Installation or
Preamble section on Technological
buildings where.asbestos products has
Removal Methods ore used" (Ex. 84-307, feasibility, Section VII). At a later
been installed and to employees who
pp. 23-24). Category C products would meeting (September 26-27,1985).
work in the vicinity of asbestos
include, under the AIA/NA's
members or the Committee noted their abatement and renovation activities.
classification scheme, products
support for many provisions of a draft
In both situations the exposures are
presenting the greatest.exposure
final standard submitted to CACOSH
occupational and are covered by this
potential. These products would ,
for review; this draft was substantively, standard. The employee's presence in
consequently be subject to the most
similar to the standard published today. the workplace places him at increased .
stringent regulatory controls.
For example, committee member Joe
risk from asbestos exposure regardless
As explained in detail above in
Adam urged that the traditional
of whether the employee is actually
. connection with the BCTD's
hierarchy of controls be reflected in the working with asbestos.
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