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INTR UCT ON

We have cOmpleted a reuiem and inuentory oF the Files which

are present in the Industrial Hygiene Department at the

The document collection dates
back to the early 1936;. in that the beginning of the 0

Department.

nlmost all of the pro?1984 document collection is contained

on microfiche cards. The microFicho collection consists of

approximately 4 feet of cards, and each card contains anywhere

FrOm one to Forty document:. In addition to the Files

maintained on Hicrofiche,-Industrial  Hygiene also currently

maintains approximately 14 File cabinets of records in hard

copy.

Micro no Record;

?Tho microfiche recorde are maintained by the Department in

'cetegories identified ee Followe:

I

(3) Plant correspondence files dated prior to

January 1. 1970. These Files are categorized by Hectinqhooce

?4eazu11



905470

 

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location There are ?85 microfiche cards in th1s category or

.documents. A representatiue sample of the types oF documents

which are contained in these files can be_ Found at Tab 1.
These Files contain a wide uariety of documents includ1nq
correspondence to and from Barnes. Speiche! and other I
Industrial Hygiene Department personnel. employe exposure
records (bio?assay. radiation, etc air sampling date,
industrial hygiene audit and trip reports, hygiene procedures,

material safety data sheets, product and chemical informationp

lists.oF chemicals used at various Westinghouse sites, plant

cleehwup Files. etc.

Plant correspondence files dated subsequent to
January 1. 1978 through 1985. There are 34? microfiche cards
in this category of documents. The types of documented

contained in these Files are the same as those mentioned in
paragraph above, with the exception of employee-specific

exposure test records such as bio?assay and radiation.' nir

sampling date is contained in these Files.

(C) Test records dated prior to January 1. 1978.
There are approximately 222 microfiche cards in this category
_of documents. These Files include air se mpling data dating

back to the 19309. employe and site specific radiation exposure

records. and employ. and site specific_bio-assay records. A

48320/2

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?Il'?representatiue sample of the types of documents which are

'cnntained in these Files can be Found at Tab 2. As stated

aboue, test records dated prior to i975 (air sampling,
bio-assay and radiation) are also.contained in the plant

corresponence files dated prior to January, 1973.

Test records dated subsequent to January 1, 1978
through 1930. There are 210 microfiche cards in this category
of documents. This category includes air sampling data.
employe and site Specific D10~assay records, and employe and
site speciFic radioactiue smear results. A representatiue
sample of the types of documents which are contained in these
Files can be Found at Tab 3. as stated above, air sampling-
data dated subsequent to January 1. 1970 is also contained in

the plant correspondence files dated subsequent to i973.

Records identified as ?Historical Files or
Industrial Hygiene Department? which date from 1930. There are
112 microfiche cards in this category of documents. These
'Files are categorized by chemical substance. and represent
essentially the Industrial Hygiene Department' 5 investigation
into various chemical substances. and contain recommendations
in regard to safe use and handling of the various substances.
These files also contain. inter alia. information concerning

previous Hectinghouso Atomic Energy Commission and state

48320/3

905472

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license: For radioactiue materia1s, a CorporaLe noise surue,

'conducted in 1974. and some_employea and site-opaciFic toot

data. A representative sample of tho types of documents which

are contained in these Files can be Found at Tab 4,

Each of the above document categories, as described above,

is maintainod separately within the card catalog.

Records Maintaingg in Hard Copy

In addition to the files maintained on microFicho. as
k'x

stated before. Industrial Hygiene also currently maintains
approximately 14 File cabinets of records in hard copy. The

hard copy recOrda are maintainad or can be broken down into the

following categories:

Plant corraspondenca files dated subsequent to
1985. These documents total approximately one File drawer. and
contain essentially the aama typos of documents as earlier

plant correspondence Filoa.



905473


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(0) \eSt records dated subsequent to 1994 These
documents total approximately two File drawers. and contain

essentially the same types oF document: as earlier test record

Files

Material cards. material safety data cheets,
purchasing department spec cards. saFe practice data sheets and
saFe practice data sheet historical Files. These documents
Fill approximately Fiue File cabinets. a representatiue sample
of an MmCard. M308, 905 card and a 5903 can be Found at Tab 5.
In addition. a representative sample oF the types or documents
which are contained in an SPDS historical File can be found at
Tab 6. These historical Files contain. at least in part. the
history oF the development of the safe handling, warning and
caution paragraphs which appear on cards, PDS cards and safe
practice data sheets. The "history" is primarily in the Form
oF correspondence to and From Industrial Hygiene. information
supplied by manufactures. brochures and technical in?ormation.

The correspondence Frequently details the dangers oF various

chemicals. products and processes.

Procedure or guideline documents. Examples oF
procedure or guideline documents which are maintained in
Industrial Hygiene Files include ?dioxin-Furan health hazard

training." radiation protection programs. radiation guidelines.



905474

.- BB 0000005

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noise reduCtion procedures, heat control procedures, 
remoual, shipment oF hazardous wasce.proceoures and ventilafwon

procedureS, to name a Few. WQStingnouse? and Industr1al
Hygiene in particular, played an active role in the deuelopme?h
0F many 0F these procedures and guidelines. An example of a

procedure or gu1dei1ne document can be Found at Tab 7

Technical literature and reports. Industrja]
Hyglone?s Flles contain a substantial amount 0F westinqhouce
generated and nonuwestinghouse generated (for example, NIOSH)

technical literature. Most of the literature is oF recent

uintage.

Federal. state and local laws and reguli?ionc

(OSHA, EPA, NIOSH, etc.) which impact on industrial hygienet

(9) Miscellaneous.

1. workmen?s compensation files (1961?prosent).
which includo pleadings. medical records, correspondence,

.results of product and chemical investigations, procedures and
technical literature.

I

2. Seminar and educational materials.



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3. Audit report and work Papers,

Records Maintained At The

Records Egg?ntion Center, Boyers, 

There are currently no hard copy Industrial Hygiene Files
at the Document Retention Center at Sayers, 
However, the ?Mines? does maintain 26 rolls 0F microFilm
records for Industrial Hygiene which are copies or the

microfiche records mointained at Industrial Hygiene.
b5

DISCUSSION



The majority of the documents in Industrial Hygieno's Files
are gotentigl ?smoking gun" documents. This is so because of
the nature. duties, obligations and responsibiliti oF the
Industrial Hygiene Department. -The approximately S7~yoars of
Industrial Hygiene Files which are in existence today are
fillgg_with technical information. procedural inFormotionu
saFe?handlinq information, hdzard intormation. recommendations
and test results. The files are filled with documentation

which critiques and criticizes. from an industrial hygiene



905476

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perspective, Westinghouse manufacturing and non?manuFaoturlng
operations. This documentdtion often times points Out
ggFigienclgi in WestingnOuse operations and suggests
recommendations to correct these deficiencies. Industrial
Hygiene?s Files contain information which details Lhe various
chemical substances used at wastinghouse sites over the yoarc_
use and



handling 0F the substanceo. The Files contain many years oF

If

employee test results, some of them unfavorable. Industrial

 

Hygiene, by performing its job. creates, daily. potenfial

smoking gun documents.

Plant Correggondongg Files

Please see, For example. lottor dated
November 7. 1960 which can be Found in Tab 1. Correspondence
oF this type was, and continues to be, Frequently generated by
Industrial Hygiene. Dr. Spoichor99 correspondence might show
early knowledge of tho Corporation to certain heath hazards
associated with epoxy resin dissolving agents. What use did
the Corporation moko of this knowledgo to protect employs: and

tho pdblic? If none or very little. than this documont might

become a ?smoking gun".



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Industrial Hygiene audit and trip reports certainly quallgg?
as potential smoking guns. lndustridl Hygiene, in each plant
.audit,?crit1ques and criticizee the Fecility From an induscrzal
nygzene perspective. Industrial Hyglene also makes
recdmmendations to improve the nygxene oF the plantt The

smoking gun of such documentation are readily

apparent.

The plant corresondence Files do. thoogh. ind1catc that For
decades Westinghouse nae had a very posit1ue and 335313
industrial hygiene department. But at least For-the peiod
'subsequent to the mid-19703, it is usually impossible to
'determine Qhat industrial Hygiene recommendations were
implemented.' The Follow?up, if any} was jus: not documented.
In addition, InduStrial Hygiene's authority regarding
Vimplementation was very limited.7 as a result. the "smoking

gun? possibilities of the-older plant correspondenee Files are

great.
Site and Emelgyo ?2393f?g-Tost Rgoordg
. 

again, it is readily apparent why some oF this

documentation might present problems. IF air sampling results,



905478?
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bio?assay te5t results and/or radiation LetL results exceed
allowable 11MIts, the possible consequences as Far as
litigation lS concerned are apparent In addition, the fact
Lrat the Corporation perFormed_ For example, air sampling For
certain substances as early as l940 (which lt in Fact did)
might be used Lo proue early knowledge on Lhe part of Lhe

Corporation of hazards associated with Such substances

Material Cards, Material Safety Data Sheets, Purchasing
?Department Specification Cards, Safe Practice Data Sheets and

.6
Historical Safe Practice Data Sheet Files 

ngain, the smoking gun possibilities of these documents are
clear. IF, FOA example. the safe practices detailed in safe
practice data sheets are not made a part of a site's induntrial
hygiene program and communicated to employes. Lhe potanial
future problems are readily apparent. In addition. if the
information is not or was not conveyed Lo customers. the

public, Etc.. again the potential Future problems are readily

apparent.



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grocedure and Guideline Documents

The discussion in the preceding paragraph applies with

equal Force here

Technical Literature

As stated before, the amount of technical literature in the
Files oF Industrial Hygiene is quite substantial, Again. this

documentation might be used to prove knowledge on the part of


the Corporation.


In order to determine whether or not to discard any oF the
records currently maintained by Industrial Hygiene. the risks
of keeping the Files must be balanced against the aduantages oF
maintaining the records} Similarly. the disadvantages of not
having records needed by the Corporation in litigation must
also be balanced against the cost and inecficiancies associated

with maintaining ualualass records. Some questions related to

these determinations include:



905480
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HhaL are the chances of litigation?- Is it pending or

imminent?

In ceSe of litigation. whicn party would have the

burden of proof?
when does the statute oF limitations run7v

what records are necessary.For Lhe conLinued opernyion.

of the Dcpartment?

whet records is the Corporation required to maintain

vpursuant to 1am?

Do the Hestinghouse records retention guidelines cover

any or all of the records?

Taking into consideration the above questions, and after
conducting legal research and a review of the Westinghouse
records retention guidelines, we recommend the following action

be taken in reference to Industrial Hygiene's Files.



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Plant Correspondence Liles (excluding air sampling data and

emplOye Lest results such as bio- -assay, radiation eLc 

These records are not reqUired pur?uant =U-any Federal.

state or local laws and/or regulations. The Westinghouse
domestic records retention guidelines do not specifically

address these records. We recommend that all Such Files

 

 

generated prior to 1974 Should be discarded. as stated before,
these recordt arc Filled with documentation dating back Lo.thei
V19305 whicn critiques and criticizes Nestinghouse operations,
and points out deficiencies in such operations.' The Files are
Filled with technical product and chemical information. hazard
inFormation and safe- handling information. of it generatgg
by the Industrial Hygiene Deg_rtment in an ?editorializinq? and
opinionated manner. The Files are not used in the daily
operation of the Department. In our opinion, the risks of
keeping these Files on the whole substantially exceed the

advantages of maintaining the records For the Following reasons:

1. The substantial bulk of the was written
_by the Department in an oditorializinq. opinionated and verbose
I manner, instead of strictly Factual. ln addition. the
Industrial Hygiene Dapartmant. prior to 1374, was involved in
testing and evaluating the safety of everything from water

coolers to gloves. From a rauiow of the Files. it appears that

4832U/l3

905482



Il'luu
Lu}: will?


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the Department commented and editorialized on just about
everything which might have been Found in the workplace. This

?self-analysis? and "editorializing? type of information can be

dangerous. This is jusL the type of documentation which should

be discarded From the Files. Correspondence generated
Subsequent to 1974, generally speaking, does not suFFer From

these drawbacks.

2. Industrial Hygiene's knowledge and know-how improued
substantially during the early 1970:. Even testing and
sampling techniques improved. Consequently, the conclusions,
guidelines and recommendatiOns as contained in the plant
correspondence Files generated prior to approximately 1974 are

not as valid and reliable as those contained in rocordf

generated subsequent to this time.

3. Industrial Hygiene Followup improved during the
19705. A major problem in dealing with the plant
correspondence Files concerns the question of what us. did the
Corporation make of the information contained in these Files.
For example. were Industrial Hygiene's recommendations
implemented at the plant level? was the body of information
generated by the Department communicated to the corporation?s
hourly employee? The publit? were Industrial hygiene?s

recommendations Followed up by the Department? There is very



905483

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_little documentary information in the ore?19705 plant
correspondence Files which helps to answer these questions.
without this inrormation, these Files Show corporate knowledge
oF hazards but no actual implementation or corrective
measures. Consequently. the documentation is potentially

harmful.

The plant correspondence Files generated subsequent to the
mid 1970s contain more inFormation concerning Follow-up and,
consequently. actual implementation of Industrial Hygiene

programs. As a result. these Files might be oF ualuc to the

Corporation. The recent request For information From the IUE

regarding PCB use at Sharon is an example of how these newer
plant correspondence Files might be oF value to the
Corporation. It might be possible to use these files. as well
as test record-Files. to establisn that industrial hygiene and
employo safety more and are promoted by Westinghouse as routine
and indispensable requirements of daily operations; to show
that health and caFoty word, and are, an integrated effort that
inuoluas management and hourly employee. Of course.
documentary auidonco of Follow-up and implementation is at
times missing From the post-19705 Industrial Hygiene Files.

Documentary auidonco oF implamantation, though, might be Found

in local plant Files.





905484

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I?lregt gecords (air sampling data. bio-assay and radiation

exposuro records, includng radiation smear results)

The Wostinghouse Domestic Records Retention Guadelines

specifically address these records as Follows:

4.07 industrial Exposure Records - Permanent ret?ntion
in employe's medical record Folio maintained in

the Human Resources/Medical Departmentc

5.05 Toxic Substances adverse Reaction Records -
permanent retention in tho Human

Resources/Medical Departments.
I -a

5.06 - Occupational radiation exposure records 
permanent retention in the Human 

Resources/Medical Departments;

.As can be seen From_thasa guidelines. each plant must

?maintain a copy of each industrial exposure record

permanently. This is similar to sbu?ral OSHR health standards,

load; arsenic. hearing conservation and benZene. whiCh

requiro poroonnol_akposuro records be maintained for various



periods, some in excess of 40 years.



905485

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The bio-assay and radiation exposure records are employee
and site specific. The air sampling data 15 site speciFi: but
data generated prior to the early l9705 is not employe
speciFiC.I>Prior to the early 19705; locations within plants
were tested. we recommend that Industrial Hygiene continue to
?maintain Lnis test and exposure'information permanently. The
records retention guidelines assign the responsibility of
permanently retaining this.lnformatlon to local human-
resources/medical departments. But until the early ?9705,
Industrial Hygiene was the department responsible for
maintaining much of this testing data. In addition, experience
has shown that often times the information cannot be 10cated at
the plant site human resources/medical departments. The
closing oF plants has historically presented problems in this
regard. Conse quently, we recommend that Industrial Hygiene.
continue to maintain the information. Based on our review of
some of this_data, it appears that at least a sobstantial
portion of it is Favorable. This information has in the past
been used to respond to Union requests for information (Sharon
is an In"

Fact, it may become even more valuable in this regard 

the doFensc of claims) if tho risk notification legislation

becomes law. . 



905486

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"Historical Files oF Industrial hygiene Department"

These records are not required pursuant to any Federal.
state or local laws and/or regulations. The Westinghouse
Domestic Records Retention Guidelines do not speciFically
address these records. We recommend_that, with the exception
0? the 1974 noise survey and the testing date whiCh is
contained_in these Files, these files be discarded. Except for
the noise survey and testing data, the other information

contained in these Files is either outdated or available from

other sources.

Material Cards, Material safety Data Sheets. Purchasina

Degartment seecification Cards; Safe Practice Data Sheets and

1 Safe Practice Data Sheet Files

 

we recommend that except For outdated and unused cards and
sheets; as well as Industrial Hygiene ?editorializing? which-is
contained in the historical SPDS Files. that this information
continue to be maintained in Industrial hygiene. 'Hard copy
cards and sheets. including outdated ones, can be Found in
multiple copies at probably every Westinghouse location.
Industrial Hygiene historically has written the safe practice

data sheets and has had. and continues to heuo. input in the

48320/18



905487

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drafting oF the sate handling, warning and caution paragraphs

which have appeared. and continue to appear. on the material

cards; material safety data sheets and the Purchasing
Department's spec cards. The material safety data sheets are
distributed to customers pursuant to the cusp hazard
communication standard and, as such, must be maintained. The
historical information, with the exception of
"editorializing-type" documents. an example of which can be
Found at Tab 6. contained in the historical safe practice data
sheet Files. provides the basis For input to the Westinghouse
materials system concerning caution clauses} SPDS references,
wastinghouse label assignments and D.O.T. classifications. It
is normally the only source of detailed cohpositional
inFormation on a chemical product being used in the
Corporation. The data has been used for spill response,
toxicity evaluation and in defense of workmen's compensation
cases. It should be pointed out that the complete corporate
history of the development of the cards and sheets is contained
on hundreds oF rolls of microfilm at Corporate Standards: It
should be noted that documents containing Industrial hygiene

"editorializing? might also appear in the files maintained at

Corporate Standards.

48320/19

905488

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prdcedur?_9nd Guideline DocumentsI Tecnnicel titereture and .

Reports. Federal, State and Local 

guidelines, Standardsv

Procedures and guidelines are prepared by Industrial
Hygiene to assist wastinghouso plants develop appropriate
occupationel health programs to minimize employe exposure and
corporate liability. Technical literature and reports are used'
to support Industrial Hygiene's corporate Functions. These
records are not required pursuant to any Federal, state or
local laws and/or regulations. The Westinghouse rec0rds
retention guidelines do not specifically address these
records. we recommend that those Files which are necessary for

the continued operation of the Department be maintain?d. Those

?mhich are no longer used and/or are outdated should be

discarded.

Mimllums 

1. ggmgensasign glgim Files. Gates, MacDonald

Company has been instructed to send a copy of all claims
involving occupational health to Industrial Hygiene For review
and defense assistance. As a result. Industrial Hygiene

maintains one file cabinet of case-specific workmen's



905489

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compensation claim Files we recommend that all settled and/or
closed Files be discardadf Ire.lluxafgtiill?JIManager,

workmen's Compensation. will be contacted to identity the

 

closed and settled Files.

2. ?gminar and Education Materials. This information,

 

along with the research and development technical library. is
used to produce the training workshops and training courses
which are presented regularly For the Facility industrial

hygiene representativest we recommend that those materials

which are necessary For the continued operation of the

Department be maintained. Those which are no longer used

and/or are outdated should be discarded.

3. Audit Report Drafts and work Papers. These documents

are generated as a result of Industrial hygiene plant audits.
Traditionally. these have been maintained by individuals
without any maintenance guidelines. We recommend that each
author discard all drafts and work paper: used to prepare the
audit report: immediately after an adequate audit response is



received from the Hestinghouse plant.

4. roF rd in he-H no . We

recommend that the microfilm records maintained at the Mines be

r-vm

destro d. These records are merely duplicates of the records

currently maintained-at Industrial Hygiene.



905490
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CONCLUSION

Toxic tort litigation, including toxic tort-related

 

unrkmen's compensation litigation. shew no signs oF abating 1n

 

the near Future. In Factl legislation such a5_the risk
.
notiFication legislation currently being considered by

Congress._will, according to many ?experts?, result in an 7 9

increase in such litigation. .Consequently, well reasoned and
I

 

conceived document uetention and destruction programs for 



departments such as Industrial Hygiene and in fact the entire-

.. . . 



Corporation. are imperatiua.



We are apailable to discuss these recommendations with you


at your convenience.

Joffr?IQ whim
Attorneya?g: ii;

 

In?! Manager
Corporate Indus?gial Hygiene

Enuironmental Affairs



905491 

- BB 0000022