Document 2JwjBNJXMr2YxMEy3KgjqK7E7

FILE NAME: Ford (FD) DATE: 1976 DOC#: FD247 DOCUMENT DESCRIPTION: Letter to the Medical Director at Ford from Johns-Manville with attached 1971 Presentation to the Illinois Pollution Control Board by Dr. Pundsack of JM Johns-Manvllle Corporation Qraanwood Plan Danvar, Colorado 80217 Paul Kollo.M. 0. Vice President Health. Safety and Environment April 20, 1976 Duane L. Block, M.D. Medical Director Ford Motor Company The American Road Dearborn, Michigan 48121 Dear Duane: Under separate cover I am forwarding a copy of Johns-Manville's ^ response to the proposed asbestos standard and I hope that you will find it of some interest. A second reason for writing relates to my desire to recruit a medical director for Johns-Manvilie. At one time or another I may have informally discussed tills with you. If not, the situation is a clear though complicated one. In my present position it is almost impossible to look both outward (regulatory agencies, legislative bodies, consumer groups and environmental groups) as well as inwardly (medical programs in a corporate situation that is beset with a "few" problems). We have managed to, in a short time, develop a biostatistical and epidemiological program of inordinately high quality, I believe, and our real need now is for a corporate medical director who is a physician in the truest sense of the word. I plan to call you sometime shortly, after you have read this letter, for the dual purpose of sparing you the necessity of writing as well as hopefully getting some helpful suggestions as to procedural approaches on my part if not actual names of persons to contact. It will be an exciting job. Ail good wishes. Cordially, CRMC-PWHD-FordMotor-000443 Dr. F. L. Pundsack Presentation to Illinois Pollution Control Board October IS, 1971________ 010088 My name is Dr. Fred L. Pundsack, and I am Vice President of Research and Development for the Johns-Manville Corporation. I am an inorganic chemist with a Ph.D. degree from the University of Illinois, and I have been involved in asbestos research i * since 1952. I am here today representing the Asbestos Informa tion Association, an organization sponsored by nine leading . manufacturers of asbestos products to provide information on asbestos and its health implications. The members of this Association are listed in a fact sheet which I have provided. . In the event that my presentation prompts questions relating . to environmental control technology or the medical aspects of the asbestos situation, I haveTasked three experts in th'ese.\ `V-; * fields to accompany me here today to assist in 'answering ques- .:/ tlons o f .a highly technical ormedical nature. `They are Dr. ,, _ - -Joseph. L>`,Goodman, .Associate Professor, Department of Preven- ^ ^ ^ ^ ^ ^ v e r ^ C t e r ^ r a t e director for Environmental Control for the 1 ' Raybestos-Manhattan Corporation; and Mr.' George L. Swallow, ;.^^vjianagar of Occupational Environmental Control, Johns-"an vi 11..;: .Corporation, 'IW -' ' 8000 1307 J/U'i i ( E PRODUCED BY FORD tv-l FAFD0009659 Before proceeding, I would like to express the appreciation of the Asbestos Information Association for the opportunity to testify on the proposed asbestos regulations. . Asbestos has numerous important applications in our modern industrial society. Among these, it provides built-in pro tection against fire and deterioration in scores of common pro ducts in daily use. Through the years it has saved countless lives and billions of dollars in property dam a g e b y 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, Oi.fice and other public buildings, and in the insulation of furnaces, boilers and electrical equipment. ' The asbestos industry within the state of Illinois plays an im portant role in the economic life of the state and its people. The member companies of the Asbestos Information Association own and operate a total of eiit plants within the boundaries of the .state. Some of the product lines produced at these eight plants include: asbestos-cement pipe, packings, gaskets, fric tion materials-- including both conventional and disc brake lin- ings--asbestos-cement sheet products, asbestos roofing and sid ing shingles, insulations, and many others. A total of 3,110 "2- 010081 flOOO 1300 PRODUCED f ly FRO PRODUCED BY FORD FAFD00Q9660 FAFD000009660 Illinois residents are enrol nvpr? PlyGd at these manufacturing faci- I" `" ' L3St yCar- " ese employees received a total q $ 24.4 million in wages Vai Trio . 9 ' salaries and fringe benefits. Services and goods purchased within the , " e State- "<* " water, electricity, telephone service, raw materi = = . . n freight amounted to more than $ 17 million in 197o m .- . ddition, state, county and local taxes amounting to nearly a minion dollars last year, helped to pay for' new schools, roads and other benefits to the state a,,d its citisens. The value of goods produced at these manufacturing locations last year totalled * ,0 .! million, with approximately ' W , -S m i l U n sold within the state. -- tos-containlng Products being " yU *" of the asbestos industrv the S U " f I U i "ois- " no means small. n,,a * . ioures * I have just given you represent only ^ ^ members of the Asbestos Information Association. There are also within'the state many other concerns - both large and small-- whose livelihood depends in <rnmf, m * v p nas in some measure on the use o asbestos or asbestos-containing products. Such concerns T O l d include many segments of the construction industry, companies engaged in the manufacture of asbestos-containing products, companies which use finished asbestos-containing p ,, d ,, ct8 in the manufacture of other pcoCcts, and ,,,ny ^ r a v , ,.. value to the state derived by the use of asbestos by these other" -- *> __ 010082 6000 l.?0q PRODUCED BY FORD FAFD0009661 concerns is difficult to gauge, however it would certainly double or triple the figures I gave you earlier with regard to the contribution of the member companies of the Asbestos Information Association.. The asbestos industry has recognized for many years that there are occupational health hazards associated with the excessive in halation of asbestos dust over long periods of time. As a re sult, the industry, beginning in the late 1920s, has sponsored and cooperated in a wide variety of scientific research projects designed to identify these hazards and to eliminate them whereever they may exist, not only in asbestos mines, mills and manu facturing plants, but also among fabricators and applicators of finished asbestos products. Today, the asbestos industry, either as individual companies or through the Quebec Asbestos Mining / Association's sponsorship of the Institute of Occupational and Environmental Health in Montreal, is supporting medical research at such highly regarded institutions as McGill University in Montreal, Tulane University in Louisiana, St. Luke's Hospital in Cleveland, the Environmental Sciences Laboratory at Mount Sinai Hospital in New York, the Industrial Health Foundation in Pitts burgh, the University of California at Berkley, Farleigh-Dickinson University in New Jersey, the University of Pittsburgh, the Medical College of South Carolina, and a number of others, both here and overseas. In addition, the industry has cooperated extensively ` ~4~ 010083 6500 13J0 PRODUCED BY FORD PRODUCED BY FORD FAFD0009662 FAFD000009662 in various investigations into asbestos-heaith conducted by agencies of the Federal Government, ihcluding the U.s. Pub lic Health Service, the Federal Environmental Protection Agency, the National Institute of Occupational Safety and Health, and others. In the industry's own research laboratories, - scientists and engineers are also engaging in work related - to health, developing safer packaging and handling techniques for loosely bound asbestos products and also developing and improving techniques for the measurement and control of as bestos emissions both in the work-place and in the ambient air. As a result of these activits, over the years the industry has amassed a substantial amount of medical knowledge and techno logical know-how in the asbestos-health area. Basically, the known facts about asbestos-related disease can be summed up as follows: ..First:, asbestos-related health risks are basically confined to the occupational and para-occupational setting. Second, the effects of excessive inhalation of asbestos are both time and dose related. This means that asbestos-related diseases may develop, generally, only afte"r''the" inhalation of' substantial amounts of asbestos dust over a substantial period of time. - ... 010084 aooo i3ii PRODUCED BV FORD PRODUCED BY FORD FAFD0009663 FFD000009663 And third, there is presently no evidence of hazard to the general public from exposure to the minute amounts of as bestos that may be present in community air. Because the general purpose of the regulations under dis cussion here today is to prevent the emission of hazardous ' . quantities of asbestos fibers into the air that the general public breathes, I w i n 'restrict.m y further comments on health to this area, it is very important to realize in any discus- . sron of a possible public health hazard frpm asbestos exposure that the.only scientific studies we have to go on are those of ^.groups of people J - n _ ^ ^ p a t ^ n ^ ^ p ara-occupation_al environments, There is no. basis for assuming that data on occupationll health '' ' risks associated with heavy, long term asbestos exposure r,n b* applied to the general public without taking into consideration ^the vast differences in.exposure between the two. Despite the fact that the only studies in existence are of occupational and para-occupational populations, a careful analysis of the data available can give us some general infor- mation about^the question of ^possible public hazard from asbestos^. The. substance of this info^Taiion'ia-thatiliselses - associated with occupational exposure to asbestos are dose re- lated and that the doses below which no.measurable increase in / ' V disease occurs are far higher than any dose to which the general public is exposed. .. -o- > 010085 800 0 131? PRODUCED BY FORD PRODUCED BY FORD FAFD0009664 EAFD000009664 evidence is based ,,,, a ,,,,mber o epidemiological studies-- three of the most prominent being one -by Dr. j. Corbett McDon.la of 10.42 past end present asbestos mining .llling Mftert n Quebec, a second by Dr. M. L. Newhousa of 4,500 men who ere employed in a British asbestos factory between 1931 and 1964 and the Third a study by Drs. Knox! Dolland associates of 87S ,,,,hers in an asbestos textile factory, also in Creat Britain. ' ' "'V HDOn*ld' in M S his subjects into eight categories, based on length of employment and severity of dust exposure. He noted that only in the highest time-exposure category comprising H v , per cent of the total, ,,as there any increase in deaths from respiratory and cardiac diseases, including l,,,,g cancer. Taken as a group, the Quebec asbestos workers had a mortality rate from all causes lower than the. level expected in the general population. 010086 Dr. .house in her study i,, great Britain found that workers who had low and moderate occupational exposure to asbestos dust showed a rate of deaths from diseases of the lung, including cancer of the lung and pleura, that were comparable with that of the general public. On the other hand, another study by Dr. Nanhouse of mesothelioma (a relatively rare cancer.of the li,,i,,, around the lungs) in the London area showed a small number of cases among people who lived in close proximity to an asLestos textile p lant and also among people living in the household of an asbestos worker. Who presumably brought home quantities of the material on his clothes -rom woik. The intensity of exposure experienced by these -7PRODUCHD BY FORD FAFD0009665 PRODUCED BY FORD FAFD000009665 aeoo 1313 so-called para-occupational populations in London is difficult to gauge, but there is every reason to believe that they were in fact higher than the low and moderate occupational levels in factories that have been shown to produce no excess of mesothelioma These studies do, however, point up the need for proper control of emissions of asbestos from factories so that neighboring areas will not suffer para-occupational exposures to asbestos. The Knox.-Doll study, like the Newjiouse and McDonald studies, ' confirmed the fact that low to moderate levels of asbestos exposure will not produce an excess of disease. It should always bo remembered that these low to moderate levels in occupational settings inside factories were certainly higher than any to which che general public in this country is exposed. . * 010087 In addition to these studies, there are several studies of the effect of various doses of asbestos on laboratory animals which also indicate that there are dose levels below v/hich no measurable disease effect is observed. Dr. William Smith of Fairleigh- Dickinson University studied mesothelioma cancers in hamsters, and his data show that below certain specific doses of asbestos, 'no cancers were observed to develop over the entire natural life span of the animals. Dr. Merl Stanton of the National Institute of Health, Bethesda, Maryland, conducted a somewhat similar study with rats and observed the same type of dose-relaced response. _ . . ' - 8- PRODUCED BY FORD BOO0 131** PRODUCED BY FORD FAFD0009666 FAFD000009666 1 Ths most WGll^knrujn *. j . the American epidemiological studies related to asbestos exposure is that- k P ro IS that ads by Dr. !. j. s,iikof Of 632 members of the Heat Frost and a u . ' - - -- ri . . - Asbestos Insulation Workers Unron x,, the. Hew Vork/He. Jersey These ^ ^ ^ " * JOttTM ^ " -- n * wort on construction - ' " teS " d *PPlY inSUUti0''." a n d hot water Papes, heating duets, etc.;, during he ^ ^ building or a power plant. T h e y ay also be involved in tearing off ,,id insulation. When one construction job is completed, they move to another construction job. ' The occupational environment to which they ,,ay be exposed involves not only asbestos but also silica ,, ,, . Tn . Sllica and particulate ms^ rta)fi in addition they are exposed to a vari7ty`qf ,,mes from" organic solvents and adhesives with whicj, they wo'rh. i,, . ! hI rt:..!;hai' a^lati^^KKi^ * - and. -in t'he " p a a T a t ' ^ . T occupational d u s t e d f u m e exposure. or. Selikoff found that the death rate fro lung cancer .was extremely high in this g r o u p of 632 workers, but that this - r y high mortality rate occurred almost exclusively among those workers who ,,ere cigarette smokers. ' 010088 On toe fangal 1-a ~ . .1. J. uhd..e workers who had no histo-y cigarette smoking had essentially ,,o greater incidence of lung cancer then the-general population of non-smokers. -9- 8000 1315 PRODUCED BY FORD PRODUCED BY FORD FAFD0009667 FFDOOQOD9667 In 9e"" 1 ' " * "Itality * worker, reported by Selikoff ls .,,,,ch higher thee the rates found i,, studies of larger groups of people ,tho ,,otk ln factorios producing asbestos-containing products, and in ,,i,,es and n s processing asbestos, why the incidence of certain ' - J diseases among insulation workers is so much higher than the Other groups studied i, .a guestion as yet unanswered. Unfortunately, as ls so often the'case with diseases that take from 10 to 10 year, to develop, reliable data as to the past occupational exposure of these men tc asbestos and O t h e r potentially hasardous dust and .fumes i,, their ' work are not available. AS a result, at the present time we have little information as to what other factors'may have influenced.their high rate Of disease except that those insulation workers who smoked cigarettes developed lung cancer at a rate far higher than the general population who smoked. In 1970, W i t h a grant f r o m the n a t i o n a l A i r f o l i a t i o n C o n t r o l A d m i n i s t r a t i o n , The n a t i o n ! a c a d e m y o f S c i e n c e s c a l l e d t o g e t h e r a b l u e - r i b b o n p a n e l of a s b e s t o s - h e a l t h e x p e r t s to draft a document oh the problem that would serve as the ' - 10- 010089 8000 1316 PRODUCED BY FORD PRODUCED BY FORD FAFD0009668 FFD000009668 1 e d i c u basis for the federal asbestos emission standards. Among those asked to serve on the panel were Dr. Clark Cooper of the university of California, Dr. Lewis Cralley of the Public Health Service, Dr. George Wright, Dr. Irving Selikoff and others. ' ' The result of their study was. fifty-three page document on asbestos/health. As a conclusion to this part of my presentation, I would like to read a few pertinent excerpts from the report, which constitutes the most up-to-date valuation of the asbestos-health problem that is available. page 20, the report states (quote)' We cannot extrapolate" / frm the n'ortalitY experience of those who are directly and indirectly exposed in their employment ti the general public^who^ave^jl^djtoderate or slight exposure from ambient _air'7 There is evidence to suggest a gradie~P~t~oFeffect--- " from direct^occupational, to indirect occupational, to'family and neighl^rhood situations, in all of which dust concentra tions are probably Eigh ty TM m ^ s o n _ w i t h ^o^t^cpmmunity _ air. This suggests that there are levels of asbestos exposure that will not be associated with any 010090 -10 a- PRODUCED BY FORD 8000 1317 PRODUCED BY FORD FAFD0009669 FAFD000009669 1 detectable risk. ,,hat those w . are ^ " no nvrd.no. that p . o ,, 5 ln the g,,,,eri|1 ^ ^ occupational, household or neighborhood expi>suces._hav<! gny increased risk of o p ! , though there ^ ,,e bodies or fibers in their.lungs (end quote], in the conclusion and recommendation section of the report for the National Academy of Sciences <->10 e n y ciences, the following statements are made: . (quote, At present, there is no evidence thlt t,,. a M U of fibers found in most members of the general population affect health or longevity. Asbestos is too important in our technology and economy for its essential use to be stopped. But, because Of the known serious effects of uncontrolled inhalation of asbestos minerals in industry. . . lt ,,ould be highly to peimit unrestricted additional contamination of the public environment with asbestos (end quote) 010091 I believe that these statements from the report adequately ex press the position of the asbestos industry with regard to the health hazards of asbastos. *e do not balieve that at present the general public is in danger from the minbte amounts of asbestos that exist in the ambient air. However we also believe that it is prudent.and feasible to establish reasonable emission c o n t r o l * * will-protect the public and ensure that hazardous levels of asbestos will not develop i,, the community air in the future. ' p r o d u c e d b y FORI1 - 11- *000 13j3 PRODUCED BY FORD FAFD0009670 FAFD000009670 position in mind, i would now like to discuss the ' asbestos r e l a t i o n s proposed f(Jr ^ ^ ^ ^ ellrt r th: ; WOUld U k e t0 '"" `S"a the Illin is PU "`i" Control Board tor ft. efforts to .ensure . safe environmonf for ,, . Stato ,,,d e u Its citizens. Vour credentials as a progredivo yat fair contro! board .re ,,ell W , n and respected in environ mental circles.throughout the nation. , ' . ' . ' 010092 While the asbestos industry =c ndustry as represented by the Asbestos Information Association is of t,,e position that thero is presently no hazard to the general public from the minute amounts of ' asbestos existing in the community air, ,,e nevertheless'are in favor of regulations designed to accomplish one or more of the following three objectives; one, to ensure the health and safety of those occupationally exposed to asbestos fiber. To, to prevent possibly hazardous amounts of asbestos fiber from escaping into the ambient air, and Three, to eliminate, where Dos<;ihira *.>, , wnere possible, the nuisance of even small amounts of asbestos fiber from escaping into the ambient air. While this third point is not directly related to health because of the small amounts of fiber involved, we wholeheartedly support the position that the environment should be as clean as possible. ' For these reasons, we suDport most of Mm. . - of the items in the proposed regulations. However, we do have several SDOcifi . ldJ- specific commonL.<; and - 12- QPOO 1319 PRODUCED BY FORD FAFD0009671 PRODUCED BY FORD FAFD000009671 1 suggestions to make regardi ' W* U be of help t "9 the regulations that we h ' r helP to the Board in , . . hoPe that w i n not o i arrj-va-ng at a fi *ot only be effective but al, . will discuss the practicai and s sections upon ,.h - . d reasonable. " der ln to -- - - Ur flrSt su9?esti0n is with cents' c,,,,. . ' th regard to Part t t . ,, ' S6Ctl0a 201. rhis Secfc.on c a u s ^neral Reguire_ Permit t0 engag^ in any activit V ^ ^ btalnln* of a fiber into y whlch could discha the environment We - , Charge asbestos SPecific e,,o,,gh ,,ith re9ird ^ " l " i . section ,,ot iS VOU P ~ t a b ly " "`in, products ,,Sed 1Ch th ` V,St " ^ would be eo,,ered. `IT sbestos- i < * with cement,.PlM t l c s eorC""trr' aSbeStS ia *-- deS "0t collstitute a source of " bl"dl"3 "aterials' and Asbestos-cement pipe an,,' viny h"118510"5 ^ ^ f ~=- b a r pj : r sibu ewssio- -- - llMaUbeoi 1 re^resent would be most wi U i - - ots in c o m o ,, use :r sr - ~ d -- / r<S9Ul3ti- -- retire " ard' A s a t i o ,, - - p a r e a list of tbos, * 10;iely'bOUnd state and thus ^ " "0"-lo`* `tf-in ' source which , nstitute a possible wnich would require * . possible, emission i -i-e a permit. , As ,, o As to Section 2oi Suh .VJ-r olio-- tion n 010093 course of health i,,struction p^"''!'"" 1''3 * " `c.tory fofustries i m ,olvi , "Ployces in those a , ng the bandlinq ot 1rt S 0i,tC>S proc'ucts, i would lih . "e r 1Sei>,'bciund _ V tG C1,1- H,a(i ' ~!3- r 000 J32o PRODUCEDBVFORD p r o d u c e d BY FORD FAFD0009672 FAFD000009672 the various trade association i,, th. asbestos industry have over the years produced a number of safety practices manuals and bootlets dealing with various sections of the industry. The Asbestos Information Association ,,,,,,Id therefore recoTM.,,d for your con- ' sidration ,, instructional material for use under Section 201, . Sub-section B, the safety practices booklets which I have s u b mitted to the Board with my presentation. The four booklets are, 1. Recommended Safety Practices for H a n d l i n g Asbestos Tiber / 2. Recommended Health Safety Practices for.Handling and Fab ricating. Asbestos Textile Products. . 3 . Recommended Practices for Fabricating. H a n d l i n g and A p p i y - rng Asbestos-Cement Products in the Building and Construe . tion Industries... and ' 4. Recommended Health Safety Practices for Handling and A p p l y ing Thermal Insulation Products Containing Asbestos. Under Part V, Section 501. it is our opinion that Subsection B, which'requires the enclosure of walls before toppling during molition, is bo^h impractical and unnecessary. We know of no suitable method for enclosing the walls of a structure ' during demolition. Even more important is the fact that there is. in reality, very little asbestos used in the construction of a modern medium-sized or high-rise structure, m addition, dust counts taken during the demolition of a building in ' ~JA~ 010094 eneo 132) PRODUCED BY FORD PRODUCED BY FORD FAFD0009673 FAFD000009673 which aid contain significant c i t i e s of asbestos products, showed very little dispersion of fiber into the surrounding air. both upwind ,,,d downwind of the demolition site. This is due to the fact that most asbestos- containing products in which the fiber is loc*ed-i,, with ce- tent. Plastic or other binding materials do not readily re lease fiber in the atmosphere ever. - ,! uapnere, even during demolition. Sub- S0C tiO H A -o f S s c t ifin -r-_ . ection 501 requires the prior.removal before toppling Of boiler and pipe i n s u l a t i o n s . t w o asbestos- containing products that might release dust from improper demolition. Since thi? n v ce this will remove any loosely-bound asbestos products from the structure, we believe enclosure of the walls to be unnecessary, and recommend that simple wetting , of the walls to be toppled would be sufficient to control the ' dispersion of dust from whatever small amount of asbestos- containing products the-walls might contain. With regard to Part VI. Section 601 of the regulations, we would like to recommend for your consirlP mh' ui you*, consideration a completely new approach to the control of aeVe . s os emissions from manufacturing _ 15 010095 . . PRODUCED BY FORD 8000 1322 PRODUCED BY FORD FAFD09674 FAFD000009674 th= _ 0/ " " y "ritten' u 'a ?ulations 3 Emeries i call foj- ^ centimeter of a . G"U "alon ^ a r d of . f. and *05 fibers or f Ctory- lr f t o * a n y nan U fa c t u r i lberS f air at th* u Parati0n# ^ n d a r y iine . - f the Plant "'e Wul<* recommend that , I T " S ^ t 0 .Subatitute a e d i l 0f tHe re9Ulations be re. . 6 *-- * numerical emiSsion *** PraCtice.standard for a8d approa(ih are * reasons for t h u ack Of specific- dat 0 the d-f th 1 A c u i t y of ac tochniques at "^ ^ ' bUt are Primarily b , to saf * n ths . G non-occupationa2 7 " msaningfup c,!si 5 concentrations _ The redecal " ' ' - a n t a ! Protp ' PrM , B V'rf =*ref,,IIy fn " d , on asb , P" Pa^ asbestos, and a d i e d this . nation . nal Mission " nUreerCal ^andard Was ^ the f u s i o n that re^ . I would like P Ctlcal a` this time. In th. -`e to read * F in this Prepared by the Epa a . ecerpts from A as justific a M . document 3ti0il for this ,, *iS dewpoint. -1 C PRODUCED BY FORD 010096 PRODUCED BY FORD anoo 1J23 FAFD0009675 The document states tht- ,, fc ideally, national emission standard for asbestos would be established on a standards related * u , related to health effects ana ,, ,, concentration basis P - t e c a TM to the ^ " " 9in " SUrCeS " * * " * ^ a p hioal considerations th* ' Ihere * Y practical -- --- Foremost of these problems is the , , is lAacolh-iin g f*roni both the health . ,, 9 ta. base-This base. stan p 7 7 or; -- ~ - -- --- exuoanr^ ' ' . * * . , : i ; : m a 3 r u y f " ta related to occupational exposure ana cannot be readily extranoi - levals y <,'rtraPJ-*to M non-oceunationai 2 T latBI ^ rePrt St<" "S th*t t^uotej a control p ,, c - t i n * ^ r Ch t0 redUln9 exposure levels offers a prac,. tape 0f " n? Ve ^ ,'U"ri0al e"1SSi" A " J~ - ~ . ' nt. With 02 P M O U C 6 Stand" d * - 1 * - in enforce- Inspectors c o m a he e,s,, y train6a to oertify co,,Bl.. a. a <-erniy compliance ol pracfcice regulations (end quote) ` 910097 r r ? 9oes n to d8c'abe - f the ---- w r P O C ia U , Blt, re3- , ,, to ' ' tons into the a n ie n t a ir , a,, d concludes that present tech - " n0t ',l y " " -- * * ~ - P e n s i v e , but th at tllov ' -17- ' ' PRODUCED BY FORD 8000 PRODUCED BY FORD FAFD0009676 FFD00000967F, 1 al* tend to distort . * . a,,d m * o f asbestQs ia ^ a actual amount of a h * ` anteston being . The National aAccaarafoemy Qf c . meanin9ful in establ * tbe . the atmosphere. healt-- X ,noted from ^ " -- , It . ^ ' " 7 " ^ and other uncertainties, it *" * -- inn of methodclogi, - -- - -a:;;;:::-; - - -- . (end quote). Vil1 not go into detail standard sin ^ rd =*n=a they ,,oula fce ' ' *Pecifics of a _ ' f " " 1 practice 1 "i U -- " t for yout '" " "" ore, ^ W - * "" -- emission Z " " " U 1 * " * * ag-,, " - e t i n f o r m a l tQ J - ^ ^ ' " - " - <* the E m ,i_ a wlll contain suf. - .. Section 602 of fart IV P * Sl"ilar ~ - r the state of ,, : ; r of a-- -- e r r a; : r t r s " ith tha - f the tate. ,.e b a U " **"* l-etems or -- y . In t,,. flrst "" section is attorns in use ,,ost # ' * Pollution control - "* effectively remove across ft TM the effluent a^ " ty Of asbestos pastes ' dlscharge into state raters. . '18- . - ' 010098 8000 32S PRODUCED BY FORD PRODUCED BY FORD FAFDQ009677 FFD000009677 Secondly, sewagfe plants iit, 9 P nts also remove asbestos fibers from J I T dUrin9 PUrifiCati0n' 111 reallt** 1 1 quantities of asbestos fibers in water high dillution a be ; 3 ised. ^ ^ ^ -- stos wastes, as cou], There is no evidence that the swallowing of small"^ mounts of asbestos constitutes any health hazard whatever. in a c t i o n , studies ,,,,ducted by Johns.Man v i U a ^ ^ small amounts of asbestos fiber in Samples of water tested from sources ,11 over tbe United States, including ,,e U and apsin, water. The reason fpr this is guit. simple. asbestos- bearing serpentine rock is to , . rocK is to be found m a majority of the U"l0n' 01., and the simple process O water flowi,,g over and through these rooks erfodes a certain amount of asbestos fiber. T us, we have all been drinking tiny amounts of asbestos i, ' or water since birth, without any discernable adverse effects. in Part VI!, Section 701 of the regdations, we.wouid reco,end the addition of the word "visible- in the next to the lasfline, no that the amended section would read: ,,o product which may emit - 10- PRODUCED BY FORD 010099 *000 1326 PRODUCED BY FORD FAFD0009678 FAFD000009678 ' . asbestos-fiber during lts t,, . , n , . soch product is enclosed in such a "" ^ -- - . -- ^ fiber r : -- ^ t0 r ClUdi " " -- " " a?ai" , . " - l y i . tec.iniques . ^ 2 ^ " ' " enforcement. The e p a hr, * (quota> "O visible emissions , ,, 5ne . . loni> (end quote) stands>-ri Similar to this one, and ,,o u W ' . circumstances also be applied in m ' ^ ^ BOard that this sections of th. p r o s e d ^ ^ 1 " "" " vould tend to be extremely aifi f . ^ e"fO"o=nt Uit not impossible. ur final comment is with _ , ' gard to Part VIT . . would prohibit the use P , Section 702, which . wie Use asbestos in the br*V i " f" " * -- X. and sold <, " ' " i" " f - * - . - a t ,,,, the basis ,, / , ^ -* evidence such a profibitio . " " *" a " completely unnecessary In ,,,,, Question ,,as investigated thoroughiy by the United St t Health Service and a - Public R L ' leprt n these i n s t i g a t i o n s by Jeremiah ** lynch, entitled "Brake rin. e^ miah - the Journal of th A " ~ -- - 't z t z ^ ~-- - t n s , only a very s m a U fraction ^ ^ 2 present in a braVe i - - ' * llni"5' P M into the atnosnh <thd quote). Lynch'found that -he ' ' . - 6 ! ^ ^ P cant asbestcs "^ ^ free fiber r e u s e d ,, . lining composition. The perco- Lhtii V ^ e r u . i n .,ho br;i,.,, c.,,qi( ;. P01CC" ^ e -- Higher only under that would have rocuJted in brak, , .. - railure. Lynch furfchsr - 20- 010100 ^000 1327 PRODUCED BY FORD produced by ford FAFD0009679 1 . ' tbft ~ * r i ty of the fiber 4,, lining3 ^ " t" M " M t -terial by the heat Qf concluded that the use of asbesto- ,, . containing brake lini,, " " "'IMnti.l health factor i,, urban ,,. xn urban air pollution." Hi. conclusion is reasonable in light of the ,, ofe cars us inn anv, , ^ that hundreds oorf mmixllliiions 9 asbestos-containing brake linings have been stopping and starting in this country for more than half a t tes been no epidemic of asbestos-related di ^ Ury' S"'d ^ ^ . . disease among the general PU " ^ W SlgnifiCant C i t i e s of asbestos been d ' ` to exist in the community air Whlle ' ^ ^-trated r tar. While we consider this evidence to be conclusive, if thc Board u tD rfrroomm bfrxaahkee l1inings, you w i n v P . y U i b0 Eii>/xronmental Protection Acrancv J * poration to do additional tesfcs " "b"` " t m " - to know that u___ .. "aa --'itractod with the in t h - the Pedaial Cen----- -" ** fnr , 1,1 t h l S a r S a * * * * s t u d y is d u e for completion in june of lc,7'? a ^ at fch ' 30(3 ^ WUld -- "-- <3 that the Board f1 7 - ' ^ ^ ~ before making b " 7 deC1S" " " aining brahe finings. lt is _ belief that the. Bendix study ,, U l confirm ,.b . " ln" 010 oohclusion reached by bynch as to the safety of asb^f. bestos-containing brake linings. . ' ' This concludes my presentation on the ' h,,,,e v thG Pt"P d regulations. I have submitted for your consideration copies of all ,, pies of all the medical papers reports, booklet, and documents that 1 ,,fbrred to I v;nn7ri 1 0lUd onco agaxn like to exnre-- t-i , r Ple* ~ U,e xn my presentation. ' ' iation of the Asbestos Information Association for the opportunity to ' - - g . Than?! you. ' ^ W ^ - 2i - 010101 P"00"CEoavrono - 8000 i323 PRODUCED BY fo r d FAFD0009680 FAFnnnnnnQtcm