Document NN2zD8Gp7Vd07jNyxp4jRE7gg

Industrial Hygiene Technical Bulletin No. 86-4 PLAINTIFF'S I EXHIBIT RT.-afi E. B. PARKER ROCKDALE UORKS 05? Date: 1986 September 11 RE: NEW OSHA ASBESTOS STANDARDS Published in the June 20 Federal Register were two new asbestos standards (see attachment 1). These include separate standards for General Industry and Construction. Major impacts of the new standards Include the following changes: - Construction Standard (1926.58) applies to all asbestos removal. - The PEL is lowered to 0.2 f/cc. Action level O.lf/cc. - Restricted areas are required where exposures exceed the PEL. - New sampling and analytical methods are required. - Monitoring requirements have been increased to "daily" for construction unless supplied air respirators are used. - Single use respirators are prohibited for any level of asbestos exposure. - Labeling is required for installed asbestos. Unlike other OSHA standards, these new asbestos rules cannot be universally applied according to industry type. Rather, the scope of each standard is related to the job activity whether conducted at a construction site or in a general industry establishment. At this writing there are some differences of opinion within OSHA as to the scope of each rule but to facilitate Alcoa's timely compliance, some specific and justifiable interpretations have been made. The majority of our exposures are during activities which are covered by the construction standard. Construction activities as defined in 29 CFR 1926.58 include demolition, salvage, removal, encapsulation, alteration, repair, and installation of materials containing asbestos. These activities are covered under the construction standard regardless of whether the asbestos-containing material is associated with the building, structure or process equipment. Other activities covered under the construction standard include emergency clean-up, transport and disposal of asbestos-containing waste. The general industry standard 29 CFR 1910.1001, covers only maintenance activities which involve the operation itself such as repairing an asbestos impregnated belt, asbestos brakes on elevators and other moving equipment including vehicles, as well as fabricating things from asbestos (machining marinite or transite). Any other activities which aren't specifically covered by the construction standard are covered by the general industry standard. The decision tree diagram at the end of this document will aid in selection of the appropriate standard to follow in each type of asbestos job. As of this writing, the only legal activities which may impact Alcoa involve an administrative problem with review by the 0MB. This has resulted in stays of several sections of each standard involving information collection (a listing of these is found in attachment 2). OSHA feels that all of the sections will be cleared without any problems but these stays may change the effective dates of some of the stayed provisions. It is recommended that Alcoa's Engineering Standard 18.18 April 1984 be followed until new construction requirements become effective. Q ALCOA ARD 003871 I.H. TECHNICAL BULLETIN NO. 86-4 / NEW OSHA ASBESTOS STANDARDS 1986 September 11 Page 2 The following information highlights key requirements of the two standards. Exposure Limits Construction 1926.58(c) effective 1987 January 16 General Industry 1910.1001(c) effective 1986 July 21 OSHA's new PEL is 0.2 fibers/cc and the action level is 0.1 f/cc. Although the effective date for construction is not until January, it will be advantageous to start using this new limit immediately in order to be able to Implement the other requirements such as training and medical surveillance which also have January effective dates. Sampling and Analysis Construction ^L9Crr5&C^), Appendix A effective 1987 January 16 (f)(2) (3) ( (stayed)^) General Industry 1910.1001 (d)^..Appaintix^A effective 1986 October 20 (d)(2), (3), (5), (7) Qstayed)^^ The frequency of sampling is dependent upon the employee exposure level as well as the standard under which the job is being conducted. As a convenience, those requirements have been included in the decision tree which follows this bulletin. Employers are required to give written notification of results to employees within 15 days of receipt. Posting of results is one way to meet this requirement. Sampling shall be conducted using a 25 mm mixed cellulose filter and cassette equipped with a 50 mm extension cowl. A 37 mm filter can be used provided justification for use (i.e., overloading) is documented with the sample analytical results. The recommended air volume for a 25 mm filter is 1 M3 with a minimum air volume of not less than 0.03 M3 (30L). Samples should be frequently checked and replaced whenever overloading is suspected. The number of open blanks required are 10% of the total number of samples taken in a particular area or 2, whichever is greater. Because of the more stringent requirements mandated in the recent OSHA Asbestos Standard, it is recommended that all samples be submitted to the Environmental Health Laboratory for asbestos fiber counting. In addition to a requirement that the NIOSH 7400 analytical method be used, which utilized a Walton-Beckett graticule for the microscope, other changes are also mandated for sample analysis. All individuals participating in asbestos counting must have taken the NIOSH Course 582 for sampling and evaluating airborne dust. A quality assurance program shall be conducted in cooperation with at least two other laboratories biannually. Samples considered "typical" for each individual laboratory shall be submitted for use in this independent program. The results of this round-robin survey shall be documented and posted in each laboratory. In addition, blind counts on 10% of the in-house samples must be made by the same counter. ARD 003872 I.H. TECHNICAL BULLETIN NO. 86-4 / NEW OSHA ASBESTOS STANDARDS 1986 September 11 Page 3 Hazard Communication Construction 1926.58(d),(k) effective 1987 January 16 General Industry 1910.1200 already in effect for SIC rnrifn Pft ^9 1910.1001 (j) effective 1986 October 20 (stayed)^) For construction, the new rule encompasses Hazard Communication Including labeling, posting, and training requirements. Contractors/employers are also required to inform other employers on the worksite of the nature of asbestos work and the requirements pertaining to regulated areas. In addition to this, the construction standard also requires the labeling of Installed asbestos where feasible. Waste container labeling is addressed under EPA's NESHAP regulations however, the new OSHA regulations specify different wording. Because EPA will accept either their own or OSHA labels, it is recommended that OSHA labels be used. These should read: DANGER! CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Regulated Areas Construction 1926.58(e) effective 1987 January 16 General Industry 1910.1001(e) effective 1986 November 17 Regulated areas must be established in areas where the permissible exposure limit might be exceeded. Such an area is posted with signs which read: DANGER! ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA The purpose of regulated areas is to restrict access. Only persons with appropriate protective clothing and respirators can enter. Eating, smoking, gum chewing and the like are prohibited in regulated areas. Under the construction standard, regulated areas must be under the supervision of a "competent person" whose responsibility is to see that these rules are followed. Area monitoring is not required under either standard but it is useful for establishing boundaries of restricted areas. ARD 003873 I.H. TECHNICAL BULLETIN NO. 86-4 / NEW OSHA ASBESTOS STANDARDS 1986 September 11 Page 4 Asbestos Abatement Construction only 1916.58(e)(6) effective 1987 January 16 Asbestos abatement activities require the use of negative air pressure enclosures whenever feasible. The exceptions are small-scale or short duration operations. An example of a small-scale job is the removal of pipe insulation inside a glove bag. Short duration operations are not thoroughly defined under the standard but they may include activities such as pipe repair, valve replacement, electrical conduit installation, dry wall removal, roofing, and general building maintenance. Respiratory Protection Construction 1926.58 (h), Appendix---*^effective 1987 January 16 1926.56 (h)(3)(i/(stayed)) General Industry effective dates: 1910.1001(g), Appendix C 8 hr TWA > 2 f/cc 1986 July 21 8 hr TWA > 0.2 f/cc 1986 November 17 PAPR 1987 January 16 1910.1001 (g)(3)(i Respiratory protection changes in these new rules will eliminate the use of single use particulate respirators for any level of asbestos exposure. Acceptable respirators for asbestos exposures are NIOSH/MSHA approved respirators selected on the basis of airborne concentrations shown in Table D-4. Appendix C which is mandatory describes fit test procedures which are required before the initial job assignment and every 6 months thereafter. After 1987 January 16, employers must provide employees the option to select powered air purifying respirators (PAPR) where they will provide sufficient protection (PF 100 X PEL). Decontamination Area and Lunchrooms Construction 1926.58 (j) effective 1987 January 16 General Industry 1910.1001 (i) effective 1986 December 16 A decontamination area consists of a clean room, shower facilities, and an equipment room in series and connected to the work area. This sort of facility is required in workplaces where the airborne exposures to asbestos are above the PEL. The construction standard allows alternatives to the requirement for hygiene facilities located immediately on the job site if employers demonstrate infeasibility. These alternatives are: o HEPA vacuum protective clothing at worksite and proceed to shower. o Change to new disposable suit at worksite and proceed to shower.. o "Small scale" jobs merely require HEPA vacuuming protective clothing before leaving worksite. Both standards include requirements for lunchrooms for employees working in areas where their exposures are greater than the PEL. ARD 003874 I.H. TECHNICAL BULLETIN NO. 86-4 / NEW OSHA ASBESTOS STANDARDS 1986 September 11 Page 5 Training . Construction 1926.58 (k)(3) effective 1987 January 16 (k)(3), (49 (stayed) General Industry 1910.1001 (j)(5) effective 1986 October 20 (j)(5i (stayed) Annual training is required for all employees exposed at or above the action level of 0.1 fibers/cc. This training must include: o Recognition of asbestos o Health effects, including effects of asbestos and smoking o Nature of job which could result in exposure o Protective measures Including engineering controls, work practices, housekeeping, PPE o Respirator fitting and use o Medical surveillance requirements. Additional information relevant to training is located in non-mandatory appendices, appendix H to the Construction Standard and appendix G to the General Industry Standard. Medical Surveillance Construction 1926.58(m) Appendices D, E effective 1987 January 1 dustry 1910.1001 (1) Appendices D, E effective 1986 November 17 A discussion of medical surveillance requirements is contained in Attachment 3 to this bulletin, prepared by corporate medical. Recordkeeping _____ Construction 1926.58 (n) effective 1987 January 16/(stayed) General Industry 1910.1001 (m) effective 1986 July 2/(itayed)) The previous rule mandated a recordkeeping period of 20 years. The new rule is consistent with 29 CFR 1910.20 requiring retention of both exposure and medical records for the duration of employment plus 30 years. Other Regulations States with their own OSHA-approved health and safety plans must revise their existing standards within six months or show that their program is at least as effective as the federal standard. Although asbestos waste is not regulated as a hazardous waste, Pittsburgh Environmental Control recommends that Alcoa Non-Hazardous Waste Manifests be ARD 003875 I.H. TECHNICAL BULLETIN NO. 86-4 / NEW OSHA ASBESTOS STANDARDS 1986 September 11 Page 6 prepared to accompany asbestos waste shipments. The only known exception is asbestos waste shipments in the state of Arkansas where Arkansas Hazardous Waste Manifests are required. There may be other state and local restrictions which apply to asbestos work. Approximately 24 states have some sort of asbestos regulations in the offing. Of these, there are 17 active state programs for asbestos control. These may requires licensing of asbestos contractors or mandatory certification for asbestos workers among other varied requirements. Refer to Attachment 4 for specific requirements and contact persons in states with active programs. Those states, as of the first of the year, include: Alabama Alaska Arkansas California Delaware Illinois Iowa Kansas Maryland New Jersey Ohio Oklahoma Rhode Island South Carolina Tennessee Utah Washington LAURA L. RIPPEY LLR:wp Distribution: I. H. Plant Contacts - Domestic I. H. Plant Contacts - International I. H. Staff - Pittsburgh & ATC I. H. Mailing List - Pittsburgh Safety, Environmental & ATC (General) I. H. Technicians Location Medical Directors Construction Field Locations T. H. Sheffield, Pittsburgh 21 ARD 003876 ^ o * -- >t Ol b --' 9 0--9 O P C O. *J oooo ! 51 2 i< fifc o o 'sU. 9 * ob k k i_ * o a >^ 3 -- C b p e o w ** -> 9 k 9 o o -- -- cooo-- ooo -- b n9CMr-<b>)b - k> o9 * 9 +k> k3 x -- u o a. *9j -- 09>99->0>v9 9 C--P Q O -- k>k>.--*C 8. c4* O i V 3 *- P -- k -- __ O 9 9 9 -- _ 4J 99 8O 9 +> k *> C 094J9-- ---- k 9 9 9 C -- O CO 9.9 e O V 9 9Q.E ^ I * 9 ft k > 93-- COXk> -- -- 9 X *> Oi 9 C -- -- 9 & 9 9 -- k ~9 9 *e 9P- 9 9 9 oo o9 c0a0. c-- 9> C-- CO o sB -- kc --4oJ--0k o 9 P 9 9 3 9 9-- 9 C -- -- -- k C C-- O O --Op--- 9 > U 4- 9 9 k O 9 C O --E 9O E 9 k 9 -- 4- 9 -- >> 9 <J 4> 9 C k O.OU9C-- 3.C -- Q w uxa.oa:o-J_i OOOOOOOO tO C -- CO >N -- -- c-- --c c --9 --k --9 9> 6 o Oi +J > a kO O3 kj U3 C9-- P --^ O 9 k 9 9 *> --9 V--_ *> 9 O 9 k> O 9 O-- k O * 4J 9 P k __ _ O -- _-- 4-> -- 9 9 C *i O -- -- 3 -- k> JD < VD>, --k e a. p c a o: u. a. x a x <r O OOOO O OOOoo C-- c-- > 0 9-- -- E * --O --Ok k-- 9 "** o o c k- *J CM C C -- r* -- --99 -* - c i 9 -- Ns. 9 a O-- E -- -- 9> --C *kJ kO> 99 ap u c 9 o ArD 003877 ATTACHMENT 2 MEMORANDUM FOR: REGIONAL ADMINISTRATORS FROM: JOHN B. MILES, JR., DIRECTOR DIRECTORATE OF FIELD OPERATIONS SUBJECT: Stay of Portions of the New Asbestos Standards Pending Review by OMB The following provisions of the new asbestos standards which contain information collection requirements are stayed pending review by the Office of Management and Budget: 29 CFR 1910.1001, as amended June 20, 1986; (d)(2) initial monitoring (d)13) monitoring frequency (periodic monitoring) and patterns (d)(5) additional monitoring (d)(7) employee notification of monitoring results (f) (2) compliance program (g) (3)(i) respirator program (j)(5) employee information and training (l) medical surviellance (m) recordkeeping 29 CFR 1926.58; (f)(2) initial monitoring (f) (3) periodic monitoring within the regulated areas (g) (6) employee notification of monitoring results (h) (3)(i) respirator program (k)(3) employee information and training (k)(4) acess to training materials (m) medical surveillance (n) recordkeeping It is anticipated that OMB will complete their review of the standards shortly. In the interim the parallel requirements of the asbestos standard issued in June 1972, as amended, and published in 29 CFR 1910.1001 will remain in effect. Please notify State Plan Designees and other program personnel of this issue. ARD 003878 ATTACHMENT 3 ADDENDUM TO INDUSTRIAL HYGIENE TECHNICAL BULLETIN ON THE OSHA REVISED ASBESTOS STANDARD (Published in the Federal Register 1986 June 20) Medical Surveillance Medical surveillance is required for employees exposed to the action level of asbestos (0.1 f/cc or greater) for 30 or more days in one year or are required to wear negative pressure respirators for protection against asbestos. Medical evaluations which meet requirements of the revised standard are as follows: 1. Initial evaluation A. Procedures Preplacement History (Standard Form - SF) Respiratory Symptoms Questionnaire (SF) Physical Examination (SF) B. Tests Pulmonary Function Test X-ray chest (PA view 14 x 17 inches) ECG Blood Count Blood Analyses (Series 24) C. Schedule: Before assignment begins 2. Annual Occupational Medical Evaluation A. Procedures Medical History Short Form (SF) Respiratory Symptoms Questionnaire (SF) Physical Examination (SF) B. Tests Pulmonary Function Test (SF) Blood Count Blood Analyses (Series 24) X-ray Chest (PA view 14 x 17 inches) - See schedule for frequency ECG - See schedule below C. Schedule for evaluation -- Annually for identified employees; X-ray chest (exposure <10 years): every 5 years; X-ray chest (exposure >10 years): a. <35 years: every 5 years, b. Age 35 <45 years: every 2 years, c. Age 45 years: annually. ARD 003879 ECG: a. Age <35 years: every 5 years b. Age 35 <45 years: every 2 years c. Age 245 years: annually 3. Occupational Medical Evaluation at Termination of Employment A. Procedures Medical History Short Form (SF) Respiratory Symptoms Questionnaire (SF) Physical Examination (SF) B. Tests Pulmonary Function Test X-ray chest (PA view - 14 x 17 Inches) Optional: Blood Count Blood Analyses ECG (Series 24) C. Schedule: Two weeks before termination from employment with Alcoa To provide medical surveillance, medical personnel must have the name of each employee exposed to the action level of asbestos (or greater) as well as the exposure level. If the employee Is required to wear a respirator for certain tasks, medical personnel should be Informed about this requirement as well as the type of respirator. Following the medical evaluation, the physician must provide to the supervisor and the employee written statements which: 1. Advise about any increased risk of employee health impairment resulting from asbestos exposure; 2. Recommend work restriction(s) if indicated; and 3. Indicate that the employee has been Informed about results of the examination and any medical conditions requiring further evaluation or treatment. ARD 003880 ATTACHMENT 4 ACTIVE STATE PROGRAMS Program contacts: 1. ALABAMA: Frank Vandiver - 205/261-4082 2. ALASKA: Rich Arob - 907/465-4855 3. ARKANSAS: Mr. Wilson [toll free] - 501/562-7444 4. OKLAHOMA: Steve Allen - 405/235-1447 5. KANSAS: Howard Saiger - 913/862-9360, Ext. 277 6. WASHINGTON: Jim Burt - 206/753-3807 7. IOWA: Walter Johnson - 515/281-3606 8. ILLINOIS: Don Anderson - 217/785-1860 9. OHIO: Marty King - 614/466-1390 10. MARYLAND: James Lewis - 301/225-5747 11. NEW JERSEY: Rich Ritota - 609/984-1863 12. RHODE ISLAND: Jim Hickey - 401/277-2438, Ext. 3990 13. SOUTH CAROLINA: Bob Betterton - 803/758-5406 14. TENNESSEE: Phyllis Blevins - 615/741-2121 15. UTAH: Larry Larkin - 801/538-6160 16. CALIFORNIA: Joanne Semones - 415/454-8588 17. DELAWARE: Bob Foster (handling in interim of finding a replacement for Frank Harris) - 302-736-5644 School Enforcement Ilazaril Aijmk:/ Assets. A p p lica b ility R e-Trng. Exam K e q u ir. 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