Document zo0MGjrJaJxLE6rLJZnaKMpm3

Comments on Proposed OSHA Standard on Workplace Exposure to Asbestos (49 FR14116, April 10, 1984) INTRODUCTION My name is John P. McGinley and I am the Vice President of A-C Pipe Opera tions for CertainTeed Corporation and a registered professional engineer. As Vice President of A-C Pipe Operations, I have complete responsibility for the manufacturing operations at CertainTeed's two A-C pipe plants, which are located at Riverside, California, and Hillsboro, Texas. My re sponsibilities also extend to the design and modification of new and exist ing process equipment for the manufacture of A-C pipe, including all the associated environmental controls. I attended Drexel Institute of Technology (now Drexel University) from 1952 to 1957, graduating in 1957 with a B. S. Degree in Mechanical Engi neering. During the five years that I attended Drexel, I spent approxi mately six months of each year working in the plants of the Keasbey & Mattison Company, manufacturers of asbestos products, including asbestos insulation and asbestos-cement sheets and pipes. Since graduation in 1957, I have been working in the asbestos products industry in various capacities--first with Keasbey & Mattison Company, and since 1962, with CertainTeed Corporation. My first 15 years were in the engineering field where I held positions including machine designer, project engineer, plant engineer, and chief engineer. For four years during this time (1959-1962), I worked exclu- CTD002048 Introduction (continued) Page 2 sively on industrial hygiene projects where I did dust level sampling in the various plants and then designed and installed local exhaust ventilation systems for the various manufacturing processes. For the past 11 years, I have worked in the A-C pipe manufacturing opera tion in such positions as plant production superintendent, plant manager, director of manufacturing and presently Vice President of A-C Pipe Operations. The purpose of my comments is to address some of the technical aspects of OSHA's proposed standard as it relates to the A-C pipe industry. While I am commenting as a representative of the A-C pipe group of the CertainTeed Corporation, I believe my views would generally be supported by my associ ates at CAPCO and JM--the other domestic manufacturers of A-C pipe. CTD002049