Document 2RDn1Bz7X9O7DdJD4z7QMZLBR
FILE NAME Roofing ROOF
DATE 1976 Jan 20
DOC ROOF010
DOCUMENT DESCRIPTION M Holberg Memo RE NPCA Action on OSHA Requirements
ParcParcRoofing
RoofingRoofing
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Cm A. J. - Noiberg 840
Internal Correspondence
aus January 20 1976
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NPCA ACTION ON OSHA REQUIREMENTS FOR OCCUPATIONAL EXPOSURE TO ASBESTOS ASBESTOS RULEMAKING
October 9 1973
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a
proposed committee committee Occupational Summary
Washington D. C.
The Nationa
Paint and Coating Association
to OSHA on
develop documents
of
comments This
task
have a tank force to as related to the industry
rulemaking
the members of the steering
force wished input from
members relating
on
roof
coatings
and
sealants manufacturer
Proposed Rulemaking
Occupational
particular to Notice of October 9 1975 Department of
in
to Asbestos dated
Exposure
Labor OSHA
to be filed with OSHA on The NPCA document is
February 9.
A draft will be sent to for commenta
committee before then
members
or before
of the steering a
representatives Primary conclusions reached by the nine mG emi beb rssproesn entTranco from Koppers
considered including has asbosTOD Paint Dab Caulk and Colonial Paint were
Tropical
substitute for asbestos in
1
There is no baskenocwnoaatvianiglsablseeals and cauike of the
This
oil or solvent
if the cost
been found to be true even
Hair was
substituto tried was 4 to 20 times higher
mimswhat affective
2 OSNA knowledge of the industry is very limited
standard of two fibers per
3 The 3 hr average proposed Further lowering as proposed
be acceptable
unacceptable to the
to 0.5 fiber per cc would be coofmplientveelsytment for compliance compliance
industry because of high
to two fibers in this
4
The necessity of lowering even
unnecessary
Ranpiratora
particular industry was thought
will be supplied by NPCA
TaT A listing of all members present
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January 30 1976
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commonly are worn posure as say for
during 30 min
the per
limited time of presibla
4 hr batch timu
ex-
5 The proposed standard in no way refers to the end
.
product application and usage but only to possible exposure
to asbestos in manufacture
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Discussion
Discussion
Members
The discussion was led by Richard Murrey Assistant Technical
Director
Standards The
9.
time for Comments
comments to OSKA has been extended to February
of MPCA will take the form of those prepared for
OSMA on Docket Substances and The draft from
SCP Proposed Exposure Ketones see copy of page of contents NPCA should be commented on 4@ soon as
attached
possible
substitutes Mineral Wool was mentioned But
Owfoultdhe tphoesssiabmleeproblem ariew with OSHA if such a fine fiber
would be used
Eric Wormeer stated they had
Gibson representative tried to find a substitute for at least 15 yr
their f~-rm
has marketed bituminous based roof coatings over 60 yr
Their development work the last 2 yr has been most intensive
Their work is continuing Uis estimate was that 150 million
of root coating is need annually 70,000 tons asbestos
gal
members generally confirmed their findings
mOyseemsetmibmeratsatatOetdhehre knew of returned truck with asbestos
abstitutes because of dui.lity dui.lity dui.lity dui.lity fellurm The success
attributed to asbestos in solvent or oil bases coatings or
sealants was the tight bond and web effect in contributing
to application properties and to long time durability and
integrity of protection
equipment document of NPCA tims would be based on uniqueness
The reply
of respirators importance of
short term exposure time usn
in the industry
industry
and knowledge of modical problems stated that out of last 15 beats
the two fiber ] times
Gibso wan s met il times and the 0.5 standard met
standard This was based on a 30 min sample time
The 8 hr time is
considered impractical with present
The long time medical record proposed by OSNA was considered 4 ; ispractical 47658
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January 20 1976
Comment with 25
was made that H
percent by weight
had been approached
of mineral spirits
on wetting fiber but did not
consider feasible
concept is being challenged challenged The TLV level asintfhoermaacttiioonnprloevgerlam by all is considered considered
A training and
desirable
Action
N
Observations of AJE
black line products No immediata
1 Consiwdietrhocua tmtuessatgienginfor durability noems available if
solution
are to be considerad
substitutes
Improved equipment for
2 Advice to coatings industry
of asbestos should be
handling pressurized andalbrleocakdytyo presmade available
available
probably is
as marketed
of N asbestos either
prewetzinghandling equipment for introduction
3 Reconsider
ex a6 ums can provide in
of
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&. A. Bengtson ~ $83
&. KR. Penner
4. B. Penner
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W. Renday 3. F. Reis
283 = 283
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