Document zokEjdXpdmJRrnK9K5850eVw7

FILE NAME Manville JMA DATE 1980 DOC JMA233 DOCUMENT DESCRIPTION Memo RE M Mexico 1980 - Planned Schedule of Major Problem Corrections . UM Manvil e Manville Chrone + Internal Correspondence W Ramiro Canizo - Mexico City ADM From W. B. Reitze WAR 1-06 Cope H. B. Moreno = Paul Kotin M.D.- Jose Grinda - WHQ 3-14 WHQ 1-06 Mexico City ADM Subport Date July 10 1980 M. Harris A. L. Cini - WIIQ 2-13 - WHQ 3-14 I was very happy to have the opportunity to meet with you in Mexico City on July 8 1980 and discuss the progress being made to correct the ADM environmental problems As promised attached is a list of problem areas and a time table for correction of these problems This list contains only the major problems that we consider to be of the highest priority You will note that there is a date for completion of each item Certain completion dates were taken from your assurances at our recent meeting If for some reason these dates are not suitable because of back- ordered equipment or delayed construction scheduling please advise and we can further discuss the dates and There are a number of items items 2 3 7 11 12 14 and 17 that require immediate action You will also note that these items do not require the expenditure of large sums of money They are merely changes in work practices Each of these changes in work practices should begin with a written ADM policy statement which should be circulated and explained in detail to all levels of supervision More important than the written document is the day to day enforcement of these work practice changes Item 17 Safety Program at all ADM Locations is listed in the context of an advisory suggestion Here as we discussed we are interested in correcting the major safety hazards those hazards that would result in loss of life or loss of limbs to an employee As discussed there are a number of Jocations in all of the ADM plants that have unguarded shafts pulleys belts and saw blades Many of these unguarded areas . pose a high risk of thereby being drawn diameter saw blades an employee getting his clothes caught and into the moving machinery The large Guadalajara pose an imminent danger of an operator losing an arm or worse there are a number of high platforms should be changed to insure that the Throughout the operations where the work procedures guard chains which for . the most part are in place are used to prevent an employee from stepping off the platform { & in re 5) nl Ramiro Canizo =2- ; July 10 1980 Your expressed plan to institute many of these changes at Barrientos first and then after the systems are better organized extend them to the remote locations is soundall However in the area of work practices I believe that all of these locations should be given attention within the next three months Your suggestion to furnish me with a status report every two months is excellent and we will look forward to your reports In addition to these reports I will arrange my schedule so that I will be able to visit the plants as well as talk with you at periodic intervals Once again I would like to remind you that we stand ready to help you in any way that we can to accomplish this environmental upgrading of the ADM operations Please do not hesitate to write or call me by telephone if there are any questions Our regular meetings during my visits to Mexico City should provide ample time for detailed discussions| tiped in F. tiped Fynne Fynne Phas 'AREAS NEEDING ATTENTION 1. Fiber feed stations at Barrientos both pipe machines and sheet machines are to have a . positive system for dust control dry or wet - including bag aside 2. Selling of empty asbestos bags at Barrientos and other plants Use of asbestos containing waste to absorb oil on floor in sheet departments at Barrientos o 4. Clean up and rebuilding of silica mill at Barrientos ; 5. Waste from bag houses at Barrientos 6. Finishing end - Pipe- at Barrientos ACTION AND DATE OF COMPLETION 1st Kollergang to be operating by October 1 1980 2nd Kollergang to be operating by July 1 1981 All necessary hooding for fiber feed stations will be reviewed for per / formance by October 1 1980 Changes necessary to correct deficiencies in hooding will be completed by January 1 1981 This practice is to cease immediately This practice is to cease immediately An oiling machine should be installed by April 1 1981 Primary crusher to be removed mine site by October 1 1980 Installation of ball mill and to dust collector as well general cleanup of silica plant by January 1 1981 Workers hand loading bag house waste by shovel for either disposal or refeed must wear respiratory pro- tective devices . An engineering solution to this problem must be in place by , July 1 1981 All finishing end machines lathes coupling offs etc. shall be either converted to wet cutting or hooded and tied into a dry collection system by July 1 1981. Methods for efficient clean of wet collection system shall be installed by January 1 1981 Page -2- AREAS NEEDING ATTENTION o 7. Dust collection system regrind at Barrientos B. Periodic inspection and maintenance program all dust collectors - all plants 9. Comprehensive housekeeping program in all ADM plants 10. Medical - program large 35 x 43 Cm rays pulmonary function testing and complete medical examination including hearing test at all ADM plants bane ddath 11. Blue asbestos fiber leed station at Villa Hermosa 12. Fluid effluent all locations ACTION AND DATE OF COMPLETION - The regrind dust collection system should be reviewed with particular attention to a regular maintenance program and a general area clean This should be accomplished by November 1 1980 - Design and institute program which : will provide assurance that all existing dust collectors are functioning properly This should be completed by January 1 1981 - A comprehensive housekeeping progran must be designed and implemented in all plants immediately This shall include prompt same shift removal of dust ser^/p spilled raw materials trash from floor . machinery and overhead ducts and beams wet sweeping only is to be used until adequate vacuuming systems can be installed at a later date Vacuuming central or boosters from existing collectors should be designed installed and functioning by Ju y 1 1981 Clinic will be completed at Barrientos fully staffed and equipped by January 1 1981 - A mechanism must be devised so that this clinic at Barrientos will service all ADM locations - A dust blue fiber feed station must be designed and installed at Villa Hermosa by January 1 1981 - Investigations and evaluations - should be made of all plants waste water discharge by July 1 198Mexican1An.y plant not in compliance with Mexican law . should begin writing plans to bring fluid effluent into compliance by January 1 1982. Exception to above time schedule would arise if Mexican government desires earlier action ba)=4thal ste me Page -3AREAS NEEDING ATTENTION 13. A comprehensive respirator program for Barrientos and Guadalajara A limited respirator program Hermosa for Villa Hermosillo Hermosillo and 14. Mexican government employment regulations all locations 15. Solid waste disposal all plants Use of sludge for storage yard and roadway surfacing Barrientos : 17. Dust collectors on mixer platforms at Quaretaro talies 18. Dust collection system and i bulk handling system for raw materials at Hermosillo aR 19. Safety program at all ADM be locations ted BRP ACTION AND DATE OF COMPLETION A respirator program designed to provide any employee working in high dust areas with respirator protection The progran must be made mandatory with disciplinary measures taken for infractions The program must be enforced by the. supervisor - A mandatory respirator program to : assure protection of workers at fiber feed stations during actual charging shall be instituted at Villa Hermosa and Hermosillo - Effective immediately all Mexican government regulations dealing with employment of under age workers must be adhered to - Beginning immediately a program should be implemented to promptly and safely remove asbestos containing waste from buildings and adjacent property Asbestos containing waste should be covered with other material at disposal site ok - Surfacing of storage yards and roadways with sludge from settling ponds should cease immediately Extremely dusty asbestos containing with roadways should be recovered a nonhazardous material - Dust collectors on mixer platforms shall be installed by January 1 1981 - A dust collection system and bulk handling system for asbestos silica and cement will be installed and operating by January 1 1981 + Beginning immediately a survey of all ADM locations should be made to identify major safety hazards These major safety hazards should be corrected within three months from date of identification Major safety hazards would include unguarded saw blades shafts pulleys and high platform walkways PPETFST vt er JM Manville ry =< Internal Correspondence M. Llano Asbestos de Mexico Chaty November 6 1980 W. B. Reitze WHO 1-06 P. Kotin M.D. H. B. Moreno J. Grinda 1-06 3-14 ADM R. Canizo ADM F. Aviles ADM R. Sustaita ADM ENVIRONMENTAL CONTROL PROGRESS ASBESTOS DE MEXICO NOVEMBER 4 1980 A. L. Cini H. J. Young 3-14 1-06 Helen Young and I met with Messrs Fritz Goebel Jose Grinda Ramiro Canizo Francisco Aviles and Ricardo Sustaita The purpose of our meeting and subsequent plant tour was to deter- the mine progress of the written environmental quality improve- ment plan First of all a few general comments It was very apparent that some progress has been made at the Barrientos location More employees than before are wearing respiratory protective devices The housekeeping throughout the manufacturing and storage areas has improved greatly There is much evidence of new work being carried on Steel work is being erected for installation of the first Kollergang The concrete weirs for water separation in the new close system are being completed The use of waste asbestos fiber to absorb oil in the corrugated sheet area has been discontinued There is evidence that the | used plastic bags are being bundled and placed in the autoclaves for disposal and I was told that the practice of selling bags has been discontinued There is evidence that the floor sur rounding the regrind system has been paved making it easier to clean The use of sludge for paving of storage yards has been discontinued and we were presented with evidence that the Board of Directors has approved step to pave these storage yards with concrete Several of the rather flagrant safety violations noticed during the June visit have been corrected that is unguarded high platforms etc. Inspection of the new clinic facilities indicated that they will be on line very shortly H. J. Young will comment in a separate report on the clinic facilities In order to more clearly discuss some of these issues I will use the list of nineteen points that I prepared and included in my July 10 memo to Ramiro Canizo ais a + ] AREAS NEEDING ATTENTION 1. Fiber feed stations at Barrientos >> both pipe machines and sheet machines are to have a positive system for dust control >>> dry or wet including bag aside 2 Selling of empty asbestos bags at Barrientos and other plants 3 Use of asbestos containing waste to absorb oil on floor in sheet departments at Barrientos 4 Cleanup and rebuilding of silica mill at Barrientos 5 Waste from baghouses at Barrientos 6. Finishing end - pipe -. Barrientos ACTION AND DATE OF COMPLETION It appears that the first Kollergang should be operating by early January 1981 ADM advised that the second Kollergang might be delayed somewhat but that the delay would not be significant The changes in the hood will be accomplishwietdh the instal- lation of the Kollergangs ADM advised that this practice has ceased and evidence indicated that bags were being placed in the autoclave for destruction Visual inspection indicated that this practice had ceased A soap solution is now being used which not only eliminates environmental problems but apparently it performs its in- tended function better than the oil ADM advised that because of problems with the supplier this entire project has been delayed for six months ADM advised that hand loading of baghouse waste materials is no longer permitted and in at least one area indicated that chutes had been extended and large plastic bags were used for collection of this material The finishing end machines are at present being converted to wet cutting Inspection indi- cated that this conversion was actually in progress AREAS NEEDING ATTENTION _? 7. Dust collection system at regrind at Barrientos ACTION AND DATE OF COMPLETION Inspection indicated that paving of the floor area around the regrind section had been accomplished Since the regrind unit had broken down and was being repaired it could not be evaluated during the inspection 8. Periodic inspection and maintenance program all dust collectors - all plants ADM advised this was still being done on a hit and miss basis but that plans have been made to incorporate this function into the duties of a newly appointed environmental engineer Mr Ricardo Sustaita 9 Comprehensive housekeeping program at all ADM plants Inspection indicated that the existing program had been auge mented greatly although | improve- ments are still needed The overseeing of this function should also be assigned Mr. Ricardo Sustaita 10 Medical program clinic This is progressing very well and will be covered by H. Young's 11 Blue asbestos fiber feed station at Villa Hermosa 12 Fluid effluent - all locations would be sufficient to remove dust This should be verified when this is fully operational verified The solution to this problem is progressing very well at Barrientos and again with the full training and assignment of Mr. Ricardo Sustaita this should progress satisfactorily mY AREAS NEEDING ATTENTION | 13 A comprehensive respirator program for Barrientos and Guadalajara Limited respirator programs for Villa Hermosa and Hermosillo | ACTION AND DATE OF COMPLETION - While the respirator program at Barrientos has been improved slightly there is a long way to go Workers were seen at many locations not wearing respiratory protective devices - One flagrant violation that should be corrected immediately is the mandatory requirement that all maintenance workers must wear respiratory protective devices Inspection indicated that none of the maintenance workers repairing the regrind operation were wearing respiratory protective devices even though they were handling asbestos fiber and clouds of dust were emanating from the workplace - Inspection indicated that workers at the feed chrysotile and blue not wearing res piratory protective devices and the air systems were not in operation ADM advised that the reason the air systems were not in opera- . tion was the fact that they were being revamped and would be com- pletely redone when the new Kollergang and collectors were put in place . - Until the dust collection systems in the new AC pipe plant are separated is material conveying and collection operators must wear respiratory protective devices This is one program that cannot wait We will| be making a special effort to pro- vide Mr. Ricardo Sustaita with aids to train workers on the im- portance of respirator programs 14. Mexican government employment regulations - all locations ~~ Despite previous statements by ADM personnel at various loca- - tions now ADM assures me that ... no under workers are being - employed nor have they been strict emplio n ty he e pad st The strict + Mexican government regulations are being adhered to and have been carina adhered to and any visual impres te sions gained during previous inspections perhaps were due to a small sized men not young boys AREAS NEEDING ATTENTION 15 Solid waste dispos^/l- all plants - . ACTION AND DATE OF COMPLETION - Although this is being looked into again ADM hopes that with the assignment of Mr. Ricardo Sustaita on a time basia ; this can be augmented 16 Use of sludge for storage yard and roadway surfacing- Barrientos . 17 Dust collectors on mixer platforms at Quaretaro 18. Dust collection system and bulk handling system for raw materials at Hermosillo 19. Safety prograamt all ADM locations advisory only ADM advised that this procedure has been eliminated and further showed me fiscal commitments for the year 1981 which would step step pave these yards ADM advised that decisions have been made to install a new dust collector when new mixer is installed The smaller dust col- | lectors now in use on the mixers will then be moved to the injection molding equipment This operation will be completed as soon as a final decision is reached on the type of large mixer to be installed ADM advised that this is being worked on The money has been appropriated for this system but it is not too clear to me what the progress will be Some of the major safety hazards have been corrected of platforms saws at Guadalajara etc. Again this function should be augmented when Mr. Ricardo Sustaita becomes fully operational I appreciate the time for some depth discussions regarding philosophical differences regardingregarding workplace safety and health These discussions discussions have helped me to understand why patience must be exer- cised I think it is also very important to say that in spite of this people at risk must be protected even if this should mean upsetting some traditional thinking In those situations requiring rather large engineering projects patiencepatience will be necessary Blow- ever in the mandatory wearing of respiratory protective devices this must be fully implemented immediately protect the health of those working with asbestos fiber ba Generally speaking I was pleased with the progress that has actually been made and I was also pleased to receive a copy of = the 1981 budget indicating the ADM Board of Directors has approved substantial sums for continuation of these projects I still feel very strongly that all of those in the ADM management must keep a continual pressure to assure that these projects are completed as soon as possible There are still employees at possible risk from . asbestos disease and this risk must be reduced immediately In response to I am arranging days regarding your request for this and this matter to have Mr. you will be Ricardo advised Sustaita trained within the next few ; In answer to your questions as to when I would return for a visit my plans currently call for a visit in the spring and you will be advised several weeks in advance At that time I will probably wish to again visit all the ADM locations W. B. Reitze