Document 1MpzmnYqaw6Od2p6BZqrO6m5

STATEMENT 013 PROPOSED REGULATIONS OF THE CITY OF DOSTON AIR POLLUTION CONTROL COMMISSION PRESENTED BY DP.. F. L. PUNDSACK, VICE PRESIDENT, RESTNECI: & DEVELOPMENT, J0HK3-MANVILLE COB? ON BEHALF OF TKI i\S-^>.ESTGS INFORMATION 201 EAST 4 2nd STREET t l * i i iOkK r "OKA ..IUU17 TION/NOETH AMERICA BEFORE THE AIR POLLUTION CONTROL COMMISSION CITY OF BOSTON APCO KIN 0001172 2/i/ll for fonto:: F. Fund:.-:, AIA/NA POSITION ON THE PANNING AND REGULATING OF ASBESTOS AND ASBESTOS-CONTAINING PRODUCTS MY W/VUT IS FRED PUNDSACA AND I AM-VICE PRESIDENT OF - RESEARCH /iND DEVELO.PMENT FOR JOIINS-MANVILLE CORPORATION. I AM HEFT: TODAY TO REPRESENT- THE ASBESTOS INFORMATION ASSO CIATION, AN ORGANIZiFTION SPONSORED 3Y THE LEADING MANUFACTURERS OF ASBESTOS PRODUCTS TO PROVIDE INFORMATION ' ON ASBESTOS AND ITS HEALTH IMPLICATIONS. MEMBERS OF THIS ASSOCIATION ARE LISTED IN A FACT SHEET I HAVE PROVIDED. I AM AN INORGANIC CHEMIST, AND I'HAVE BEEN INVOLVED ASEZ5T0S RESEARCH SINCE 1952. ASBESTOS HAS NUMEROUS IMPORTANT. APPLICATIONS IN OUR MODERN. INDUSTRIAL.. SOCIETYAMONG-THESE IT-P.RO.V:IDES,,BUILT-IN-> PROTECTXON. ` AGAINST" EIREi AND..DETERI'ORATTONviNT'SCOJRESr:-OFTCOMMONT PRODUCTS' IN' DAILY;.'. USET-' THROUGH- THE::YEARS' "ITVHA'S.-'SAVED.'COUNT:-- ' LESS LIVES. AND BILLIONS OF DOLLARS IN PROPERTY DAMAGE BY PREVENTING .OR CHECKING THE.SPREAD OF.FIRES. ASBESTOS-CONTAINING. ACOUSTICAL PRODUCTS MAKE A VALUABLE'CONTRIBUTION TO NOISE ABATEMENT.' PRODUCTS CONTAINING ASBESTOS ARE'USED, AMONG OTHER APPLICATIONS IN THE CONSTRUCTION OF SCHOOLS, HOUSES, THEATERS, FACTORIES, OFFICE AND OTHER PUBLIC BUILDINGS', AND IN THE INSULATION OF FURNACES, BOILERS AND ELECTRICAL EQUIPMENT. THE ASBESTOS INDUSTRY HAS RECOGNIZED FOR MANY YEARS CAPCO KIN 0001173 3/4/71 P.2 THAT THERE ARE OCCUPATIONAL HEALTH HAZARDS ASSOCIATED WITH' THE EXCESSIVE INHALATION OF ASBESTOS DUST OVER LONG PERIODS OF TIME. AS 'A RESULT, THE INDUSTRY HAS. SPONSORED AND COOPERATED IN A WIDE VARIETY OF SCIENTIFIC RESEARCH PROJECTS ' . DESIGNED TO IDENTIFY THESE HAZARDS AND TO ELIMINATE THEM WHEREVERTHEY MAY EXIST, NOT ONLY IN ASBESTOS MINES, MILLS, AND MANUFACTURING PLANTS, BUT ALSO AMONG FABRICATORS AND APPLICATORS OFFINISHED ASBESTOS PRODUCTS. THESE EFFORTS HAVE RESULTED IN THE DEVELOPMENT OF'EFFECTIVE MEASURES AND TECHNOLOGY FOR THE CONTROL OF ASBESTOS DUSTS THROUGHOUT INDUSTRY. IN RECENT YEARS, THE USEI OF CERTAIN ASBESTOS-CONTAIKING , PRODUCTS IN' HIGH-RISE BUILDING CONSTRUCTION,. PRIMARILY ASBESTOS- rnM^j THTvr cpin.v nierir iiutamc HAS. BEEN CALLED 'INTO.QUESTION 3ECA OF. SUPPOSED PUBLIC HEALTH HAZARDS ASSOCIATED WITH ,-THE USE--OF......... R - SUCH PRODUCTS: DURING APPLICAT.IONA-AND -.THE.:EVENTUAL.;DEMOLITION " ... i.-. ** - if-^ ' - : *. . .. * \ ,/ f. OF BUILDINGS CONTAINING THE'' PRODUCTS..: ' PROPOSALS TO REGULATE THE USE OF ASBESTOS-CONTAINING SPRAY .> ' MATERIALS HAVE BEEN ADOPTED IN SEVERAL .CITIES- AND; STATES ACROSS THE COUNTRY. ' ' ' ' ' THE ASEESTOS INDUSTRY WHOLEHEARTEDLY SUPPORTS THE ` ADOPTION OF REGULATIONS DESIGNED TO PROTECT SPRAY AND . OTHER CONSTRUCTION EMPLOYEES FROM EXPOSURE TO POTENTIALLY HAZARDOUS AMOUNTS OF ASBESTOS OR ANY OTHER FORM OF-DUST i" CAPCO KIN 0001174 3/4/71 P.3 IN TIIEIR WORK, AND ALSO SUPPORTS EFFORTS TO REDUCE OR ELIMINATE TIIE NUISANCE OF SMALL AMOUNTS OF DUST UEIWG ALLOWED TO ESCAPE INTO THE COMMUNITY AIR HOWEVER, THE INDUSTRY IS OPPOSED TO THE COMPLETE BANNING OF ANY USEFUL MATERIAL, INCLUDING ASBESTOS-CONTAINING PRODUCTS, ON THE UNPROVEN. SUPPOSITION.TEAT ITS APPLICATION OR USE UNDER THE PROPER OPERATING CONDITIONS MAY 'PRESENT A HEALTH HAZARD TO THE . GENERAL PUBLIC. . ;. IT HAS NOT BEEN DEMONSTRATED THAT ASBESTOS IS A PUBLIC HEALTH HAZARD. THERE IS NO EVIDENCESCIENTIFIC OR OTHERWISE, THAT ANYONE IN THE GENERAL PUBLIC HAS EVER CONTRACTED ANY DISEASE FROM EXPOSURE TO THE MINUTE AMOUNTS OF ASBESTOS THAT MAY BE RELEASED INTO THE AIR'AT'CONSTRUCTION ;OR DEMOLITION V;-:. SI1 ASSOC IA' REL.ATED, AND THE DOSES BELOW .WHICH NO'MEASURABLE ' INCREASE" IIT DISEASE OCCURS ARE FAR HIGHER THAN ANY DOSE TO-. WHICH; THE ' GENERAL-.PUBLIC -IS EXPOSED.- THIS EVIDENCE.-.IS ;BASED;ON;. A* STUDY- BY ^j*'l. ,4;', DR. NEW1IOUSE OF 4500 MEN WHO WERE .'EMPLOYED 'IN' A BRITISH ASBESTOS FACTORY BETWEEN 1933 AND 196 4. IN THIS STUDY, DR. NEWKOUSE' FOUND THAT THOSE WORKERS WHO HAD LOW AND MODERATE EXPOSURE TO ASBESTOS DUST DID NOT SHOW ANY INCREASE IN DEATHS FROM DISEASES OF THE LUNG INCLUDING CANCER OF THE LUNG AND CANCER OF THE PLEURA ' THAN THE GENERAL POPULATION. IN THIS STUDY IT' IS SAFE TO ASSUME THAT THE LOW AND MODERATE LEVELS OF ASBESTOS DUST TO.WHICH' THESE . WORKERS WERE EXPOSED ARE MANY TIMES TIIE LEVELS 'OF, ASBESTOS, CON CENTRATION IN THE AMBIENT AIR TO WHICH THE GENERAL. P1.:"'. .. II CAPCO KIN 0001175 3/4/71 P.4 IN CONNECTION WITH AMBIENT AIR CONCENTRATIONS OF ASBESTOS FIBER, IT IS WORTH NOTING THAT RECENT INVESTIGATIONS SHOW THAT SMALL QUANTITIES OF ASBESTOS FIBER FROM NATURAL SOURCES MAY HAVE EXISTED IN TIIE COMMUNITY AIR FOR THOUSANDS OF YEARS WITHOUT MEASURABLE ILL. EFFECT ON HUMAN BEINGS. -.IN- ADDITION TO THE STUDY OF BRITISH ASBESTOS FACTORY WORKERS BY DR. NEVTliOUSE, THERE ARE SEVERAL STUDIES OF THE EFFECT OF VARIOUS DOSES OFASBESTOS ON LABORATORY ANIMALS ' WHICH ALSO. INDICATE THAT THERE ARE DOSE LEVELS BELOW WHICH NO MEASURABLE DISEASE EFFECT IS OBSERVED. DP.'. WILLIAM SMITH,-' . FAIRLEIGH DICKINSON UNIVERSITY, -STUDIED'MESOTHELIOMA CANCERS..-^; a -- IN HAMSTERS, AMD 1-IIS DATA SHOW THAT EELOW CERTAIN-SPECIFIC DOSF5 C- 7-SRESVns.. NO CANCERS WERE OBSERVED TO DEVELOP OVER ; THE ENTIRE NATURAL LIFE SPAN OF THE- ANIMALS. DR. -MEARL .STANTON'-^j OF THE NATIONAL... INSTITUTES OF HEALTH,' BETHESDA, CONDUCTED A SOMEWHAT. SIMILAR-STUDY'WITH'RATS^ SAME TYPE OF DOSE-RELATED RESPONSE. . .FOR THESE REASOI- UNWARRANTED TO BAN ............ ....... MATERIAL, INCLUDING SPRAY INSULATIONS, IN BUILDING OR OTHER CONSTRUCTION.. FROM A PUBLIC HEALTH STANDPOINT, SUCH A BAN IS COMPLETELY UNNECESSARY. THE PRIMARY CONCERN OF ANY LEGISLATIVE OR REGULATORY EFFORT SHOULD, THEREFORE, BE DIRECTED AT PROTECTING. _ THOSE OCCUPATIONALLY EXPOSED TO ASBESTOS DUST AND TO. TIJE CONTROLS NECESSARY TO MINIMIZE OR ELIMINATE ITS EMISSION FROM -PLACES . WHERE ASBESTOS IS BEING PRODUCED AND APPLIED. PAST EXPERIENCE HAS SHOWN' .THAT SUCH CONTROLS ARE POSSIBLE, ECONOMTT1*^*^ ;APCO KIN 0001176 3/4/71 P.5 AMD EFFECTIVE. FOR ADDITIONAL INFORMATION, WE ARE ATTACKING THE FOLLOWING DOCUMENTS TO THIS STATEMENT: -1. "A Natural Mineral Fibre," Ontario Research Foundation Newsletter, 'Vol. 13, No. 9, "November 1970 (Describes asbestos and its uses) - 2. Asbestos and the General Public (An Asbestos Information Association background paper which deals in health research in connection with asbestos) "Asbestos and Health in .1969" by Dr. George W. Wright/./. reprinted from Aider. Review of Respiratory Disease, .' - - V'ci.-' 100, No. 4, October 1969 (Examines in detail the .- . current status .of ' the asbestos-health situation) `. ...... *' : ^ .. "Partnership/for Preventi-ohrrThe Tnsu 1 aticnpIndus.tryja Hygiene Research Program,by Dr. Irving J. Selikof/. ** ^ "` J. " ` - f reprinted from Industrial Medicine and Sufaery, Vol . ' --r_ " .. .. No-.: 3; (Discusses accomplishments of program -.to-develop' - ....: ' .. . '. - .. / ; . r : .A..-'- .i.. - VS' . " ..... means .to protect insulation'workers from asbestos., dusts) -. -- " 5. ".Source and Identification of Respirable Fibers" by Lewis.`)J.. Cralley,et al., Amer. Industrial Hygiene Association Journal, March-April 1968 (Discusses the . various types of fibrous materials found in the air and their ability to form-so-called "asbestos-.bodies") 6. `"A Study of the .Mortality of V,'others in an Asbestos "' ". . v:- Factory" by M. L. Newhouse, reprinted from Bri.t. J. Ind. Medicine, Vol 26, pp 294-301 (1969) i' CAPCO KIN 0001177 3/4/71 P. G "Experimental Pulmcn.ary Carcinogenesis with Asbestos" by Maori F. Stanton, R. lilac''.wo 11 and E. Miller, reprinted from Amer. Industrial Hygiene Association Journal, Vol. 30, pp 236-244, 196.9. . ` 'i ' # ' #' . ! . V CAPCO KIN 0001178