Document 2jQmY7Q5jE6RqExyn9M7jLGnr

CertainTeedH October 10, 1983 TO: All A/C Pipe Plant Employees As you may be aware, the U.S. Environmental Protection Agency (EPA) has announced that it is considering a ban on certain jnhpg-tas-ggqtaininq productsf not necessa rTfy ~bec'ausT tTiey pose a health hazard, but as an initial step in an effort to limit use of asbestos fibers in the U.S. Categories under consideration for a product ban are roofing and flooring felts, asbestos felt-backed vinyl flooring, vinyl-asbestos floor tile and A/C pipe and fittings. These products were selected, not because they present greater risk than other products (as a matter of fact EPA freely admits that the reverse is probably true), but rather for throe basic reasons as follows: o These products >jr<? large volume users of asbestos fibers and discontinuation of their use and production would significantly reduce the amount of fiber to be mined. 0 Use of these products Is finite. That Is, banning them would not affect other products such as automobiles, pumps, stoves, etc, o In EPA's opinion, there are readily available substitutes for them. In our opinion, EPA's thinking is totally unjustjfied and we are strongly opposing this effort. Following is additional '"Th format ion that may be PSTpful to you in understanding the situation. This action, if taken by IPA, would bn taken under the authority of the Toxic Substances Control Act (T.SCA). In order to impose any regulatory requirements under TSCA, EPA must show that the manufacture and use of a product presents an "unreasonable risk of injury to health or the environ ment." Substantial evidence must be presented after consideration of a wide range of risk and benefit factors. And, EPA must use the least burden some requirements to regulate "unreasonable risks." Finally, such regulatory action requires public hearings. If CPA proceeds with proposing a ban on A/C pipe, CertainTeed nnd the industry would vigorously participate in the hearings in order to protect our interests and we are confident we can justify our position. OVOI' Based upon current practices, we believe it is safe to manufacture and use A/C pipe, In fact, many agencies, including the government, for many years have been studying the health effects associated with the use of A/C pipe and there is no evidence to conclude that this product poses a hazard to public health. For over a decade, CertainTeed and the A/C pipe industry have shared EPA's interests that commercial and industrial use of asbestos and A/C pipe be as safe as scientifically and economically feasible. The industry has acted responsibly. CertainTeed and other A/C pipe manufactuiers not only have complied with various federal and state laws regulating the use of asbestos, but have bettered them. Today, as you know, the manufacture of A/c pipe is virtually a closed system: asbestos fiber handling and pipe machining arc automated; process water and solid waste are recycled; state-of-the-art filtration systems eliminate 99.9% in air discharges to the environment. Also, detailed work practices have been n-ide available to contractors and installers of A/C pipe. These present proven methods of Cutting, beveling and tapping pipe to insure a safe work environment;. EPA's current thinking clearly ir not based on sound scientific judgment. You can be assured that we are working diligently to fight this attempt to ban A/C pipe and avoid the unnecessary loss of jobs to CertainTeed employees whose dedication and loyalty is valued by the Company, John P. KcGinley Vice President A/C Manufacturing