SCENARIO
€ Small company (50 employees) engaged in manufacturing bonded asbestos products: President directs operations himself, with assistance of a small staff, including production supervisors.
€ Plant Conditions:
- Poor housekeeping: (e.g. loose fibre on the floor, empty asbestos bags lying around; waste material accumulating on machinery and building structure; broken bags in storage and production area).
- No Industrial ventilation system
- Conveyors not enclosed
- Visible dust concentrations at debagging and mixing stages
- Respiratory protective equipment not provided to workers
- No lockers, washing facilities, work clothing provided to workers
- Establish corporate policy to be a responsible employer and provide a healthy and safe working environment;
- State this commitment in writing. Have it signed by the President and circulate it to all employees (see Appendix-I);
- Join local industry association
- Assign responsibility to a senior production supervisor to develop and implement a preventive and control program;
- Engage outside expert(s) (within or outside industry association), to undertake full evaluation of plant with following objectives:
(a) Establish baseline airborne concentrations at all stages of the production process and in all areas of the plant using personal and static sampling techniques;
(b) Identify all sources of dust and cost-effective solutions to reduce exposures to acceptable levels;
(c) Establish priorities and cost of preventive and control measures to ensure compliance with all regulatory requirements.
- Establish joint health and safety committee, complete with management and labour representatives, with meetings to be held on a regular basis (see Appendix-II for minutes of a typical meeting held in Canada).
- If necessary and as an interim solution, outfit workers exposed to high concentrations of asbestos (e.g. where Permissible Exposure Limit is exceeded) with appropriate respirator and personal protective clothing and provide training on use and maintenance;
- Establish detailed plan of action complete with problem areas, proposed solutions, estimated time and costs, milestones, etc.
- Visit other companies, industries to obtain technical solutions, learn from their experiences, etc.
- Implement a dust measurement program to evaluate airborne concentrations of fibre on a regular basis;
P.S. If a company is under pressure from regulatory authorities to demonstrate compliance, a copy of the company's policy statement and action plan could be registered with authorities thereby ensuring adequate time is granted to comply with regulatory requirements.
- Implement immediately all dust control measures which require no capital cost (e.g. repair broken bags; clean all floors and equipment, building structures using wet methods; establish housekeeping schedules to ensure waste does not accumulate from shift to next).
- Provide appropriate lockers, washrooms and eating facilities;
- Establish training programs for workers to ensure they understand clearly desired work practices and why they are important;
- Undertake another evaluation of airborne fibre concentrations in the plant to determine progress.
- Undertake all relatively inexpensive control measures, such as enclosure of conveyor belts and those parts of the production process which can be a source of fibre emissions;
- Purchase or fabricate enclosed debagging or feeding station; isolate this station from other parts of the plant.
- Introduce wet dust control techniques where practical (e.g. cutting and sawing stations);
- Purchase HEPA filtered vacuum devises to clean floors; to decontaminate workers clothings, etc.
- Invest in an industrial ventilation system to ensure that all enclosed systems operate under negative pressure and air ventilation capacity is available to all debagging, mixing, grinding and cutting operations;
- Ensure all hoods are properly designed and effective;
- Introduce regular maintenance schedules to ensure proper functioning of the industrial ventilation system;
- Provide training to all workers impacted by the introduction of this technology;
- Undertake another evaluation of airborne fibre concentrations to verify compliance with regulations.
- Initiate study of waste production, handling and disposal;
- Implement all process changes necessary to minimize waste production and maximize waste recycling;
- Implement all appropriate procedures to ensure waste is disposed of according to national regulations.
- Implement a medical surveillance program of workers with qualified medical doctors;
- Prepare a report to government authorities demonstrating that your company is in compliance with all regulatory requirements.
- Implement active research and development program to continue progress in developing low-cost, practical dust control measures with aim of lowering exposure levels to the lowest level practicable;
- Develop product stewardship program targeted towards customers and users of your products;
- Prepare annual report to government (company or industry wide basis);
- Actively participate in national industry association (e.g. by organizing matters on industry wide basis more cost effective access to necessary expertise and services could be available, yielding significant economies to all member companies).
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