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 ade om J - * BT) Manville w meno to File Cm A. J. - Noiberg 840 Internal Correspondence aus January 20 1976 Cop Sac Below oun NPCA ACTION ON OSHA REQUIREMENTS FOR OCCUPATIONAL EXPOSURE TO ASBESTOS ASBESTOS RULEMAKING October 9 1973 5 4 ; B : , ; , 4 ; " id e 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 | Pain . 4 car aa . a te i aa meet . i . . aba 2, na ! i, 4 lete ad . . F? . . 4 Mumo to File =3- January 30 1976 ak ; 4 : 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 r z 4 4 4 : Bs 3 , 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 Be i r a 4 % }: Lh: 4 f 4 E 4 i * a 2 q } a a 4 - , meno to File o}+ 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 / Hoch wei Attachment oc: a. 4. Snow - 362 &. A. Bengtson ~ $83 &. KR. Penner 4. B. Penner - 48} -o2a W. Renday 3. F. Reis 283 = 283 Ja. anpleenr - 2B - . B. Shepherd 5S