APPENDIX 2: STEWARDSHIP AND PRODUCT RESPONSIBILITY PROGRAM AND PERFORMANCE MEASUREMENTS FOR SYNTHETIC VITREOUS FIBERS

Exposure Assessment

To establish a database that allows assessment of exposure conditions, trends and specific controls.

Format and categorize by product and task pre-1990 exposure measurements (3-5,000 samples). Implementation year 2 (2001).

Format and categorize by product and task post – 1990 exposure measurements (1-2,000 samples). Implementation year 2 (2001).

Format and categorize by product and task exposure measurements available in the literature or from other organizations. Implementation year 2 (2001) and 3 (2002).

Develop a sampling strategy designed to target higher potential exposures such as: loose-fill installation; removal activities combined with demolition activity; tightly enclosed, poorly ventilated space applications; fabrication with hand-held power cutting tools, such as saws; compressed air cleanup; mineral wool manufacturing; mineral wool ceiling tile installation; special application fibers; batt insulation installation; and removal of unjacketed high temperature insulation exposed to service temperature of above 177¡ C/350¡ F. Implementation year 2 (2001) with sampling beginning year 3 (2002).

Develop a sampling strategy designed to verify exposures during manufacture fabrication, or use of products with traditionally low potential exposures and to assess exposure levels of new products. Implementation year 3 (2002) with sampling beginning year 2 (2001)

Develop procedures to ensure database integrity and that the database includes sufficient data to access current exposures by collecting approximately 400 samples annually. Implementation year 3 (2002) and continuing through compliance year 5 (2007).

Quality Assurance

To provide independent validation of exposure assessments.

An auditing team will be established to validate exposure assessments. Implementation year 2 (2001).

Training

To develop educational material and provide information regarding potential hazards, appropriate work-practices, and exposure controls.

The following information will be provided to OSHA on an annual basis starting Implementation year 3 (2002) and continuing through Compliance year 5 (2007):

	Number of training sessions conducted
	Number of "trainers" trained
	Number of people present at training seminars
	Number of videos, brochures or other material distributed

NAIMA also commits to complete one "Train the Trainer" session that will train 10 trainers within the first 24 months of the implementation phase of the HSPP. In addition, during that same 24-month time period, NAIMA commits to 10 geographically diverse worker-training sessions. NAIMA also commits to conduct an additional 20 worker-training sessions within the first 36 months of the implementation phase of the HSPP.

User Intervention and Customer Service

To determine best work practices, and promote continuous improvement in appropriate handling and use of insulation products through employee and customer involvement.

The following information will be provided to OSHA on an annual basis starting Implementation year 3 (2002) and continuing through Compliance year 5 (2007):

	Narrative reports on the most effective control measures and work-practices.
	Facilitate documentation of user work-practices using questionnaires.
	Number of individuals or companies requesting on-site intervention.
	Add Partnership Program and accompanying brochures to NAIMA’s web site and track number of hits. Implementation year 2 (2001).
	Manufacturing companies with established seminars or training courses taught by certified industrial hygienists will invite by letter SVF users/customers to attend these seminars and training courses. Where possible, these manufacturing companies will provide NAIMA with the number of users/customers attending the training courses.
	NAIMA will identify respirator manufacturers and distributors that provide free respirator fit testing and training, and NAIMA will then provide the names of those manufacturers and distributors to employers and workers handling SVF products. The list of manufacturers and leading distributors will appear on NAIMA’s web site and in NAIMA’s literature promoting the Health and Safety Partnership Program. NAIMA will categorize these manufacturers and distributors by region.
	NAIMA members with 1- 800 numbers that supply health and safety information to employees and other workers exposed to SVFs will provide NAIMA with an approximate number, when available, of worker safety information inquiries per year. In turn, NAIMA will forward this information to OSHA, without identifying the companies providing the data, in the annual report to be submitted by NAIMA.
	NAIMA and its members companies will circulate annually a questionnaire that asks manufacturing workers and manufacturers’ customers to indicate the safe work practices they employ on a regular basis. NAIMA will provide a summary of these questionnaire results in the annual report submitted to OSHA.
	Where SVF insulation products are sold by large, nationwide, retail outlets from which contractors may purchase SVF products, NAIMA and its members companies will provide, where feasible and appropriate, workers safety information.

Governmental Partnership

To provide periodic briefings to OSHA and other interested Parties.

Number of sessions and content will be mutually determined.

Research

To continue a program of basic and applied research on new product formulations or where data are deemed insufficient to determine potential risks, or effective controls.

Manufacturers with medical monitoring programs will provide annual reports to NAIMA on their programs. NAIMA will provide OSHA with this information in its annual reports to the Agency.

NAIMA will conduct studies with respirator manufacturers to measure the efficacy of various respiratory protection devices (specifically the N95 series) in limiting potential exposure to SVFs.

Validate protocols to assure appropriate bio-solubility of insulation products. Implementation years 1 (2000), 2 (2001) and 3 (2002).

Identify independent laboratories for conducting quality assurance testing for insulation products. Implementation year 3 (2002) and throughout Compliance years 1-5 (2003 –2007).