PAGE: 1 OF 14 I. PURPOSE ASBESTOS PROGRAM The Lake Charles Asbestos Program has been developed to establish work practices, engineering controls, training programs, industrial hygiene monitoring, and medical surveillance. These procedures will insure that protection is provided for all employees, contractors, and the environment. This will result in compliance with all applicable corporate policies http://ehs.web.ppg.com/pdfs/10/11/101129.pdf and governmental regulations. II. DEFINITIONS A. Amended water means water to which surfactant (wetting agent) has been added to increase the ability of the liquid to penetrate ACM. B. Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these materials that have been chemically treated and/or altered. C. Asbestos Containing Materials (ACM) are defined as any material or product which contains more than 1% (by weight) asbestos. D. Class I asbestos work means activities that involve the removal of TSI and surfacing ACM or PACM. E. Class II asbestos work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos containing wallboard, floor tile, and sheeting, and roofing and shingles, and construction mastics. F. Class III asbestos work means repair and maintenance operations, where ACM, including thermal system insulation and surfacing material, is likely to be disturbed. G. Class IV asbestos work means maintenance and custodial activities during which employees contact ACM and /or PACM and activities to clean up waste and debris containing ACM and/or PACM. H. Competent Person means one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure. This individual must have a 40 hour Supervisor s course from a DEQ certified trainer.
PAGE: 2 OF 14 I. Friable asbestos - These products can be easily crumbled using hand pressure alone to release airborne fibers of asbestos. Examples of friable ACM are: bulk asbestos, asbestos insulation, asbestos fireproofing, and asbestos cloth, rope or paper. J. Non-Friable asbestos - These products contain asbestos, but it is tightly bound within some other material. They cannot be easily crumbled by hand pressure alone. Fibers will be released due to friction wear, cutting, scraping, or other mechanical action. Examples of non-friable ACM are: transite (asbestos cement) sheeting; asbestos gaskets, and impregnated valve packing; asbestos brake shoes and clutch linings; and asbestos impregnated floor tile. K. Employee Exposure means that exposure to airborne asbestos that would occur if the employee were not using respiratory equipment. L. Fiber means a particulate form of asbestos 5 micrometers or longer, with a lengthto-diameter ratio of at least 3 to 1. M. High-efficiency Particulate air filter (HEPA) means a filter capable of trapping and retaining at least 99.97 percent of 0.3 micrometer diameter mono-disperse particles. N. Presumed asbestos containing material (PACM) means thermal system insulation, sprayed on or troweled on surfacing material and debris in work areas where such material is present. O. Regulated Area means: an area established by the employer to demarcate areas where Class I, II, and/or III asbestos work is conducted, and any adjoining area where waste and debris from such asbestos work accumulate; and in areas where airborne concentrations of asbestos exceed, or there is reasonable possibility they may exceed, the permissible exposure limit. P. Surfacing material means material that is sprayed, troweled on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes). Q. Thermal System Insulation (TSI) means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain. III. GENERAL:
PAGE: 3 OF 14 A. Sources of Potential Asbestos Exposure at Lake Charles Potential asbestos exposure at Lake Charles can be categorized into three groups. 1. PPG Bipolar Electrolyzer Chlorine production Production jobs which involve processing bulk asbestos for electrolyzer diaphragms; cleaning old diaphragm elements; deposition new diaphragms; assembling new cells; and "doping" active cells. 2. Electrolyzer-related maintenance work Maintenance jobs/work orders which are associated with Electrolyzer chlorine production. Examples of this would be maintenance work on Renewal Shop(s) equipment, particularly that associated with "processing rooms" or laborers assigned to unload shipments of asbestos. Also, some maintenance work involves equipment that has remaining traces of asbestos contamination. a) Examples of this would be repair or rebuilding electrolyzer elements, and "fattening" electrolyzer anodes. 3. Maintenance work such as: B. Controlled Areas a) Jobs involving friable asbestos or fireproofing materials Example of this is stripping asbestos insulation or jacketing from process equipment or piping, repair/removal of transite siding, will be done by a certified Asbestos contractor. b) Non-friable asbestos containing material Examples include asbestos gasket removal/replacement, removing cleaned valves, repairs in fluff room, service on equipment, jobs involving the old "black" Haveg Chemite pipe, and brake or clutch repair work. c) Any activity/work performed near friable asbestos could cause accidental release or damage to ACM. Entering a vessel where PACM could be disturbed. d) Custodial/Maintenance activities in which work is done near ACM or PACM (janitorial/cleanup work).
PAGE: 4 OF 14 1. Regulated Areas All Class I, II, & III work shall be conducted within regulated areas. All other operations covered by this procedure shall be conducted within a regulated area where airborne concentrations of asbestos exceed, or there is reasonable probability they may exceed a IPEL. 2. Non-friable Asbestos In general, areas or work which involves non-friable asbestos materials in good condition does not normally require the establishment of a controlled area. However, work which will generate airborne fibers of asbestos must be performed in a controlled manner. a) Where hand tools are used and the non-friable asbestos may be wetted (either with water or another agent) no special controls are needed other than such housekeeping steps to prevent contamination of the work area. b) Where handtools are used and the non-friable asbestos may not be wetted (due to process, material, or other considerations) an "asbestos area" must be temporarily established and appropriate protective steps taken. c) Whenever non-friable asbestos material must be machined, drilled, cut or ground using high-speed power equipment, a "regulated area" must be established unless special dust capturing local exhaust equipment is used. When local exhaust equipment is used, a "Regulated Area" must be temporarily established. C. Medical Surveillance Program All persons who must work in a "Regulated Area" must be included in the Lake Charles Asbestos Medical Surveillance Program. This involves in-house preassignment and annual examinations for PPG employees and certification from contractors that their employees have had similar examinations. Details on examination content and approval criteria are given in Section V. D. Air Monitoring for Asbestos and Exposure Limits Personnel and area air monitoring is conducted per the current Lake Charles
PAGE: 5 OF 14 Industrial Hygiene Sampling Strategy where potential asbestos exposure exists. Results of such monitoring will be communicated to affected employees and supervisors. The OSHA exposure limit for asbestos is 0.1 fibers/ml air. OSHA also provides an "excursion limit" of 1.0 fibers/ml averaged over 30 minutes. E. Regulations Concerning Asbestos The Occupational Safety and Health Administration (OSHA) has established two separate regulations which address the use and handling of asbestos. CFR 1910.1001 - the general industry standard. This applies to our Bipolar Electrolyzer Chlorine production operations and associated maintenance work, and by specific reference - brake/clutch repair activities. CFR 1926.1101 - the construction industry standard. This standard applies to all other jobs dealing with asbestos or asbestos containing materials, including removal of friable asbestos materials and insulation, transite siding, and asbestos cement piping, and gaskets. Copies of both OSHA standards are available for review from your Area Safety Representative or from the Plant Industrial Hygienist. Finally, the U.S. EPA and LA. DEQ also have a number of regulations concerning asbestos. Refer to Section IX or contact Environmental Department for details. F. Lake Charles Policy 1. Asbestos or asbestos containing materials (ACM), other than as necessary in production facilities, will not be purchased for new installation at Lake Charles. Engineering specifications exist which prohibit the use of asbestos in any form as an insulation material. Exceptions to this must be co-approved, in advance, by the Manager, Engineering & Maintenance and the Manager, Safety & Health. PPG will not perform any Class I or II asbestos work. All Class I or II asbestos work will be contracted out to a certified contractor. 2. Records of asbestos abatement projects including: abatement project design records, asbestos air monitoring results, post-abatement photos, applicable medical records, disposal records and training records shall be maintained.
PAGE: 6 OF 14 G. Identification of Asbestos All insulation, pipe covering, pipe, and gaskets must be presumed to be asbestos, unless verified through a legitimate source. Visual determination is not allowed. Sources include testing, records showing material of construction, existing labeling, or knowledge of previous scope of work identifying the material in question. 1. Asbestos testing a) A bulk sample can be obtained for identification. The area supervisor where the material is located will contact either Industrial Hygiene (IH) or the Field Engineer trained as competent person to arrange for an LDEQ licensed asbestos inspector to obtain a bulk sample. Work will proceed based on the results of that sample. 2. The material may be assumed to be ACM and treated as such in lieu of bulk sampling. Contact either IH or designated Field Engineer to proceed. H. Job Planning and Responsibilities 1. The owner/planner of area where ACM is located shall: a) Review the job to determine if the work falls within the general industry or construction scope. The competent person shall be consulted in making the determination. b) Contact the competent person for their area (see Section III.H.2) at least 24 hours in advance to supervise the job. c) Notify and communicate to affected personnel the nature and extent of work to be performed including work areas to be restricted and approximate length of time of job. d) If the job is to be contracted out, contact the environmental group per the guidelines given in Section IX., of this policy to comply with notification requirements if applicable. Class III jobs are estimated on an annual basis and do not require a case-by-case notification. 2. Removal/Renovation of ACM Competent Person All asbestos/assumed asbestos removal/renovation jobs must be supervised by a competent person. Roger Cormier, field engineer, is the
PAGE: 7 OF 14 current Supervisor trained and certified by the State of Louisiana. Contractor removal/renovation jobs will be supervised by their own competent persons with PPG competent persons (field engineers) as coordinators. 3. All removal/renovation work involving friable ACM shall be reported to the PPG competent person at least 24 hours in advance. The competent person shall: a) Coordinate and supervise the removal/renovation job per all applicable regulations and PPG corporate policy. b) Complete asbestos removal safe work practice and disposal checklist for each job and forward to environmental secretary within 2 days of completing job. c) All area air monitoring data collected by PPG and abatement contractors during asbestos abatement work shall be entered into the PPG IHIS system referencing the asbestos abatement project by name or project number. d) Visual inspections shall be performed prior to re-occupying all asbestos abatement areas to assure that dust has been cleaned from surfaces. e) Photographs shall be taken after planned asbestos abatement project completion to document that all work was performed in accordance with removal specifications and that the space was acceptable for occupancy post removal. Photographs do not have to be taken of small scale asbestos abatement projects. Refer to the corporate policy for definition of small scale. IV. COMMUNICATIONS OF HAZARDS TO EMPLOYEES A. Warning Signs and Barricades 1. Posting - Warning signs must be posted at the entrance to and perimeter of all controlled or regulated areas. Areas which are not defined by walls or other permanent barriers are to be barricaded using yellow barricade tape with an asbestos warning imprinted.
PAGE: 8 OF 14 2. Specification - Warning signs shall be in the standard OSHA "danger" format and read: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONS ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA B. Warning Labels 1. Labeling - Warning labels shall be affixed to or imprinted on all containers, bags, etc., which contain asbestos, asbestos slurry, scrap, or asbestos containing material, debris, scrap, etc. 2. Specification - Labels may be in any format provided the following information is included: C. Employee Training 1. Minimum Required Training DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD PPG - LAKE CHARLES All employees that are exposed or potentially exposed to asbestos, will receive annual training on: a) Lake Charles Asbestos Program b) Health Hazards of Asbestos c) Restricted Areas and Jobsites d) Work practices for ACM e) Recognition of ACM or PACM f) OSHA regulations g) Smoking Cessation program availability 2. BiPolar Electrolyzer Operations & Related Maintenance All employees (and their supervisors) potentially exposed to asbestos as
PAGE: 9 OF 14 part of the electrolyzer diaphragm operation or related asbestos contaminated maintenance work will receive initial and annual training. This training will cover: a) All minimum required training listed above, b) Required personal protective equipment, c) Proper operation of engineering controls, d) Required housekeeping procedures, e) Description of the plant Medical Surveillance Program, f) Work practices necessary for safe handling of asbestos. 3. Custodial Workers a) All custodial workers will be given 2 hour awareness level training that will consist of: (1) All minimum required training listed above. (2) Required personal protective equipment (3) Description of Medical Surveillance Program. (4) Required work practices. V. MEDICAL SURVEILLANCE PROGRAM A. Employees Included The Medical Department maintains a roster of all PPG employees who must work in a Regulated Area and are medically approved for such work. Contractor personnel are responsible for maintaining their own programs and records and are subject to program audits by PPG. Supervisors must notify the Plant Nurse in advance of any personnel changes which will affect this list. Employees who are not presently participating in the asbestos Medical Surveillance Program must be examined and approved prior to their new assignment. Individuals who terminate their employment for any reason will also be offered an exit examination. Such employees may be eligible for continued health surveillance under the PPG Health Care Policy. Contact the Medical Department for further details. B. Content of Asbestos Examination Each employee will be examined by the Plant Physician prior to assignment and annually thereafter. The examination will include:
PAGE: 10 OF 14 1. Medical and Work History Questionnaire, 2. Pulmonary Function Tests (FEV 1 and FVC), 3. Chest x-rays (with interpretation by a "B-reader" certified radiologist), per the schedule given in 1910.1001(l)(3) - Table 2. 4. Physical examination by the physician, 5. Any additional testing deemed necessary by the plant physician. C. Medical Approval Criteria - The Plant Physician will determine, based upon test and examination results, in his opinion whether an employee has any detected medical condition(s) that would place the employee at an increased risk of health impairment from exposure to asbestos (or asbestos containing materials). In the event of such determination - the employee will not be approved for asbestos work. Employee Notification - The Plant Physician will inform each employee of the results of his/her examination and the presence of any medical condition which may be related to asbestos exposure. The employee will receive a copy of the written physicians opinion/approval within 30 days of the examination. Supervisor Notification - The employee's supervisor will be notified by the Medical Department in writing of any asbestos related work restrictions. Confidentiality - The Plant Physician will not reveal, in any written opinion given to the employer, any specific findings or diagnoses unrelated to occupational exposure to asbestos or other workplace hazards. VI. PERSONAL PROTECTIVE EQUIPMENT (PPE) While engineering controls and work practices generally reduce asbestos exposure levels, personal protective equipment is the final barrier against asbestos exposure. A. Respiratory Protection 1. All provisions of the Lake Charles Respiratory Protection Program must be observed. Selection of the level of equipment required is based on the table below. a) Asbestos Fiber Count Respirator Unknown Pressure-demand airline w/escape provisions >100 Pressure-demand airline w/escape provisions
PAGE: 11 OF 14 B. Protective Clothing 5 to 100 Pressure-demand airline 0.1 to 5 Full-face mask w/asbestos or HEPA filters 0.01 to 0.1 Half-mask w/asbestos or HEPA cartridges 1. Disposable coveralls w/hood & feet - Tyvek or similar impervious material. 2. Rubber boots (so that any contamination may be rinsed off.) 3. Gloves - (any type is permissible, but must be disposed of after use). VII. PERSONAL HYGIENE A. Decontamination 1. Employees required to enter regulated areas must wear full protective clothing (not over street clothes). Change rooms with separate "clean" and "dirty" locker areas must be used. If change and shower room (with "dirty" and "clean" locker areas) are not adjacent to the work site, then two sets of coveralls must be used (one worn over the other). When leaving the regulated Area, decontamination is to be performed as follows: a) Vacuum off protective clothing and respirator. Remove outer coveralls and respirator. Proceed to a shower facility (a designated shower facility is not required). Shower and change to street clothing. b) If a designated shower facility is adjacent to the regulated area, vacuum off protective clothing, proceed to dirty room, remove protective clothing, shower (with respirator in place) and change into street clothes in the clean room. *All employees working in a regulated area shall have facilities and time available for showering at the end of a work shift. 2. Food or Tobacco Consumption a) Employees may not eat, drink, smoke, chew gum or tobacco. b) The employee must exit the regulated area - after proper decontamination steps are taken - and wash their hands and face prior to eating, drinking, smoking, etc. c) No employee may enter a lunchroom with contaminated equipment or clothing.
PAGE: 12 OF 14 VIII. HOUSEKEEPING A. All surfaces will be maintained free of any accumulation of asbestos or wastes containing asbestos. B. All spills or sudden releases of asbestos will be cleaned up immediately using wet methods or a HEPA vacuum. C. Compressed air shall not be used to clean surfaces or clothing contaminated with asbestos. D. All vacuums used for cleaning must be equipped with a HEPA exhaust filter. Special care must be taken when emptying such equipment to avoid re-entry of asbestos fibers to the workroom air. E. Vacuuming and/or wet wiping is the preferred method of cleaning. Shoveling, dry sweeping without a HEPA vacuum, or other dry methods of cleaning are not permitted. IX. ASBESTOS NOTIFICATION GUIDELINES & DISPOSAL A. Contact the Environmental Department for guidelines and forms on Asbestos Notifications for the following operations: 1. Chlorine Production (process wastes) 2. Non-scheduled operations (Individual asbestos insulation removal jobs of less than 1 cubic yard). 3. Planned Operations (Asbestos insulation removal equal to or more than 1 cubic yard). Environmental must be notified at least 10 days in advance on all jobs > 1 cubic yard 4. Emergency Operation (Caused by sudden, unexpected event and involves asbestos removal equal to or more than 1 cubic yard). Environmental must be immediately on all jobs > 1 cubic yard (LDEQ requirement) Items 3 and 4 above require a separate Asbestos Disposal Verification Form. B. Louisiana Department of Environmental Quality regulations currently require asbestos disposal at a site approved for asbestos and industrial solid waste. Contact the Environmental Department for guidelines on proper disposal.
PAGE: 13 OF 14 X. WORK PRACTICES A. Non-Friable Asbestos 1. Many products within the Lake Charles Plant contain non-friable asbestos and do not pose any hazard under normal conditions. But any action which causes fibers to be released does result in a potential hazard. General for handling a variety of non-friable asbestos items are given below. 2. The purchase of ACM gaskets and has been phased out, but due to the fact that there may be isolated cases where ACM gaskets are still in use, the following work procedures on replacing ACM gaskets is included. When piping and equipment is dismantled, the surfaces of the connection must be inspected for the presence of a gasket. If a gasket cannot be identified as non-asbestos (rubber, graphite, flexitalic) a certified asbestos inspector must be called to sample and identify the gasket as asbestos or non-asbestos. A gasket identified as containing asbestos will be removed by the PPG asbestos abatement contractor. 3. Jobs involving cutting or abrading the surface of Piping must consider the possibility of asbestos piping. If the piping can be verified to be nonasbestos as in section G above, it must be tested. B. Bi-Polar Electrolyzer Operations 1. Work procedures for operations use of asbestos are extremely detailed and are covered in Plants A & C unit SOPs. C. Maintenance Work Associated with Electrolyzer Operations 1. Cell elements or equipment associated with Electrolyzer Chlorine production are to be cleaned before being released for maintenance work. 2. However, emergency repairs of contaminated equipment or trace contamination of cell elements being worked on require certain precautions to be followed. See Plants A & C Maintenance SMPs.
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