Why Yard Work, Even Nearby Work, Carried High Exposure
The process of the work is what drove exposure. OSHA ties heavy exposures in ship repair to "the removal of asbestos materials due to renovation, repairs, or demolition." The VA explains the mechanism in plain terms: exposure "can be a serious health risk if asbestos-containing material is disturbed in such a way that the particles and fibers become airborne." OSHA notes that the fibers "are too small to be seen with the naked eye."
Ship repair and breaking meant cutting into, tearing out and replacing insulation on boilers and pipes that NCI says were insulated with asbestos. OSHA states, "There is no 'safe' level of asbestos exposure for any type of asbestos fiber," and that exposures "as short in duration as a few days have caused mesothelioma in humans." NCI says risk increases "with heavier exposure and longer exposure time," yet investigators have found asbestos-related disease "in individuals with only brief exposures." A short stretch in a yard does not by itself rule the exposure out.
Many former yard workers ask what it means if they never handled insulation but worked nearby while someone else did. Whether a nearby worker breathed fibers from another trade's work is a factual question about the job, the space and the time. Coworker accounts and job records often help answer it.
Exposure could also travel home. NCI reports "some evidence that family members of workers heavily exposed to asbestos face an increased risk of developing mesothelioma." It attributes this to fibers "brought into the home on the shoes, clothing, skin, and hair of workers." The site's page on secondary asbestos exposure covers that pathway.
The federal shipyard standard reaches these kinds of work. In its own words, 29 C.F.R. § 1915.1001(a) covers, among other work:
"(1) Demolition or salvage of structures, vessels, and vessel sections where asbestos is present; (2) Removal or encapsulation of materials containing asbestos; (3) Construction, alteration, repair, maintenance, or renovation of vessels, vessel sections, structures, substrates, or portions thereof, that contain asbestos; (4) Installation of products containing asbestos; (5) Asbestos spill/emergency cleanup; and (6) Transportation, disposal, storage, containment of and housekeeping activities involving asbestos or products containing asbestos, on the site or location at which construction activities are performed."
The section adds that coverage "shall be based on the nature of the work operation involving asbestos exposure." It also says the section "does not apply to asbestos-containing asphalt roof cements, coatings and mastics." OSHA describes what its standards require of employers, including exposure monitoring, hazard awareness training, regulated areas, engineering controls, protective equipment and medical monitoring when legal limits and exposure times are exceeded. The existence of a rule does not by itself show what happened at any particular yard. That is something the records and witnesses have to show.