Page One

To the Editor: 

In early February 2002, several East Bay Municipal Utility District (EBMUD) employees expressed concern to Cal/OSHA about possible exposure to asbestos in roofing materials at district reservoirs. Eight of the district's 186 reservoirs have roofs constructed of corrugated transit paneling that contains asbestos. These eight reservoir roofs were constructed in the 1960s. 

In response to the employees’ concerns, the Alameda County and Contra Costa County Cal/OSHA offices began parallel investigations. In mid-June, the Alameda County office concluded its investigation and issued five citations, four of which the district is appealing. Then in mid-July, the Contra Costa office issued eight citations for similar violations at two additional locations. Six of these citations are being appealed because the district disagrees with Cal/OSHA's interpretation of the regulations. More specifically, the district believes that Cal/OSHA has an incorrect citation for the event and did not consider the notifications to employees made by the district and, most importantly, the district has demonstrated that there was no employee exposure above the Cal/OSHA permissible exposure level. 

As information concerning this issue became available, EBMUD responded immediately by testing the water supply to ensure no impacts, which was confirmed by the test results. Additionally, the district initiated an assessment of conditions at all eight reservoir locations to determine if asbestos was present at concentrations that would pose any potential human health or environmental issues. The district conducted air quality tests to determine if the workers, while performing their tasks, might be exposed to harmful levels of asbestos particles. The test results were far below Cal/OSHA's permissible exposure level. 

In summary, the district has taken this issue very seriously and has taken appropriate actions to ensure the protection of public health, employees, and the environment. The Cal/OSHA citations appeal process is expected to be resolved in 16 to 18 months. 

David Richardson 

Director, Ward 4 

Berkeley