PAGE 1 OF 5 HEALTH, SAFETY & ENVIRONMENTAL MANUAL PROCEDURE: S520 Asbestos Exposure Procedure REV /31/09

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1 PAGE 1 OF 5 Purpose: ASBESTOS EXPOSURE CONTROL PROGRAM To define the Company s asbestos exposure procedure. Procedure: IT IS COMPANY POLICY NOT TO WORK IN SUSPECTED OR KNOWN ASBESTOS- EXPOSURE ENVIRONMENTS THAT WOULD RESULT IN THE IMPLEMENTATION OF AN ASBESTOS EXPOSURE CONTROL PROGRAM. PRIOR TO ACCEPTANCE OF ANY JOB THAT WILL POTENTIALLY EXPOSE THE COMPANY PERSONNEL TO ASBESTOS, REGIONAL MANAGERS SHALL CONTACT THE PRESIDENT OF THE COMPANY TO FULLY DISCUSS ALL DETAILS OF THE PROPOSED WORK. SUCH DISCUSSION SHALL BE PRIOR TO UNDERTAKING ANY ACTION THAT WILL BIND THE COMPANY PERSONNEL TO PERFORM SUCH WORK. Before the Company may allow employees to work in an environment which contains asbestos a study must be completed by a qualified entity to determine: 1. Time Weighted Average exposure to asbestos fibers is not in excess of 0.1 fiber per cubic centimeter of air as an eight hour time weighted average exposure per the standard referenced in OSHA code Appendix A. 2. That an Excursion exposure limit does not exceed 1.0 fiber per cubic centimeter of air over a 30 minute average per the standard referenced in OSHA code Appendix A. Or 1. That recent monitoring satisfies the requirements of OSHA standard (d)(2) in verifying that permissible exposure limits shall not be exceeded. 2. There is sufficient objective data to demonstrate that asbestos concentrations shall not exceed the permissible exposure limits. Note: Exposure monitoring as required in OSHA must be reinstituted if there is any change in the production, process, control equipment, personnel or work practices that may result in new or additional exposures above the specified limits. The Company shall comply with all OSHA requirements regarding workplace monitoring for asbestos as defined by the OSHA standard (f). Results of these monitoring

2 PAGE 2 OF 5 sessions must be communicated to affected employees as soon as possible, but not more than 5 days after the Company receives the results. This notification is to be communicated individually or posted in an area readily accessible to the affected employees. Employees and their representatives are allowed the opportunity to observe monitoring. Upon request the Company must provide them with proper protective equipment, and allow them to observe the monitoring procedure. All asbestos monitoring must be properly documented and records are to be kept for a minimum of 30 years. These records must include: 1. The date of the measurement 2. The task for which the monitoring is representative 3. The sampling and analysis methods used and evidence of their accuracy 4. Number, duration and results of the samples collected 5. The type of protective equipment worn 6. Name, social security number and exposure amount of all employees for whom the sample is representative. No employee may be exposed to asbestos levels in excess of the PEL defined above. In the event that PEL are exceeded in the work environment: 1. A written program must be created for the reduction of exposure amounts to below the PEL using methods such as engineering controls, work practice controls, and the use of respiratory protection according to OSHA and Work practices and engineering controls must conform to the standards listed in OSHA (g). These controls and practices must be designed to reduce employee exposure to below the PEL, and maintain those levels. 3. Respirator selection and use must comply with the Company policy S190. Respirators are provided at no cost to the employee for use in emergencies, work practice controls, work operations and to reduce exposure. These respirators must be chosen from those approved by NIOSH. All employees who are required to use respirators shall be familiar with the proper use, fitting and limitations of respirators per OSHA 29 CFR Employees working in areas where the PEL for asbestos is exceeded are to be issued and required to wear proper protective equipment including but not limited to coveralls or other suitable full body protection, gloves, foot coverings, vented goggles, face shields and head coverings. These items are to be provided and maintained by the company at no charge to the employee. (ref S150) 5. Laundering and cleaning of used protective equipment must be performed such that it does not release airborne asbestos in excess of the PEL defined above.

3 PAGE 3 OF 5 6. In work environments containing asbestos that are controlled by another party the Company shall ensure that the work site is compliant to OSHA standard before allowing its employees to begin work at the site. 7. Areas in which asbestos exceeds the PEL shall be controlled access zones demarcated by signs proclaiming: DANGER ASBESTOS, CANCER AND LUNG DISEASE HAZARD, AUTHORIZED PERSONELL ONLY. If respirators and protective clothing are utilized to reduce exposure in these areas to below the PEL then signage must also be provided stating: RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA. Employees working in areas near asbestos regulated areas must be aware of the meaning of these signs. 8. Employees working in controlled access areas may not eat, drink, smoke, chew gum or tobacco or apply cosmetics. 9. Only competent trained persons trained and monitored in accordance with the Company s asbestos exposure control program may enter and work in asbestos controlled access zones as defined above. Medical Surveillance: Employees who are exposed to asbestos work environments which exceed the PEL or are engaged in Class I, II, or III work as defined by OSHA for more than 30 days per year are to be included in the Company s medical surveillance program. All medical examinations and procedures are to be provided by a licensed physician at no charge to the employee at a reasonable time and place. Employees who are to be monitored under this surveillance program shall be examined within 10 days of their 30 th day of exposure, and at least annually thereafter unless the examining physician determines that examinations must be provided more frequently. For each employee requiring medical examination the Company must supply to the physician: 1. A copy of OSHA appendices D, E and I 2. A description of the affected employee s duties as they relate to asbestos exposure 3. The anticipated exposure level to which the employee will be subject 4. A description of the personal protective equipment and respirators that the employee will be required to use 5. Any information regarding previous medical examinations of the employee to which the physician might not otherwise have access.

4 PAGE 4 OF 5 Examinations shall conform to the guidelines indicted by OSHA (m). Records of all examinations must include: 1. The name and social security number of the employee 2. A copy of the examination including medical history, questionnaire answers, test results, and the physician s recommendations 3. The examining physician s written opinions 4. Any employee medical complaints regarding asbestos exposure 5. A copy of the information provided to the physician Training: Prior to allowing any employee to work in an area where asbestos exposure may exceed the PEL the Company shall provide training to its employees which explains the hazards associated with asbestos in terms that they can understand. This training will be carried out by a qualified person and properly documented. The record of this training shall be maintained at the Company s corporate office for at least one year after the end of the employee s tenure with the Company. Training is to be repeated annually or when conditions change which require further employee awareness such as change in work type, location, engineering controls or when an employee is observed to be failing to meet the company s standards to limit exposure to asbestos. Training content for employees who will work in areas where asbestos exposure may exceed the PEL shall be decided by the OSHA standards listed under (k)(9) depending upon the work type to be performed and the engineering controls in place at the work site. This training shall be provided free of charge and shall include: 1. Methods for recognizing asbestos. 2. The health effects of asbestos exposure. 3. The affect of smoking in combination with asbestos exposure in producing lung cancer. 4. Details about the amount, form, use, release and storage of asbestos on the proposed job site. 5. Engineering and work controls to be used on the site to reduce employee exposure 6. The procedures that will be in place to protect employees on site including PPE and their use, proper work practices, clean-up procedure and emergencies 7. Appropriate work practices for dealing with asbestos 8. The requirements of the Company s medical surveillance program 9. The content of OSHA and it s appendices 10. The names addresses and phone numbers of public health organizations which provide assistance in smoking cessation ( appendix J)

5 PAGE 5 OF 5 Written material including the applicable OSHA standards, site specific hazards and other relevant training information will be provided to employees at no cost. The Company shall inform employees about the existence of self help smoking cessation programs and at an employee s request shall provide NIH publication number or its equivalent which is approved or published by one of the health organizations listed in appendix J.