Document 37mn9gxG8Qr2KM1n6QJMkK6Yy

FILE NAME Roofing ROOF DATE 1986 June 25 DOC ROOF007 DOCUMENT DESCRIPTION Brief Presented to the EPA by Power Marketing Group Inc. - Relating to a Proposal to Phase Out Asbestos with Cover Letter from Power MG - Manufacturer of Asbestos Roofing Felts r Power Marketing 9745 E. Hampden Ave. Suite 420 Denver Colorado USA 80231-4924 Group Inc. OPTS Docket 23 62036 M Asbestos Ban File we LES rr ae Telephone 303 695-4803 84+ Telex POW POWE ER R DVR JIN 26TH FAX 303 695-8388 June 25 1986 Document Control Officer 793 Office of Toxic Substances Environmental Room 209 Protection Agency 401 M St. S.W. Washington D.C. 20460 Re OPTS - 62036 i 1986 1986 JUN 20 Dear Sir The attached Brief has been prepared by Power Marketing Group Inc. Power Marketing Group Inc. is the exclusive marketing agent of the manufacturer of asbestos roofing felts These products are sold in the United States through approximately eighty seven distributor outlets We trust that informative you will find the enclosed information useful and Yours truly H/Power IO J. P. Power President A7 Encl BRIEF PRESENTED TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RELATING TO A PROPOSAL TO PHASE OUT USES OF ASBESTOS Prepared by POWER MARKETING GROUP INC 9745 E. Denver Hampden Ave. Suite CO 80231-4924 420 303 695-4803 Asbestos felt has been used in roofing applications since 1910. The unique qualities of asbestos fiber are particu- larly suited in the use of roofing felt Asbestos fiber is non- rotting resistant to the effects of ultraviolet rays and remains stable under changing atmospheric conditions It is for these reasons that asbestos felt has been used in thousands of applica- tions throughout the world In more recent years asbestos fiber in itself has proven to be a carcinogen Documentation and publication of this illness has provided a negative response often unwarranted to any product obtaining asbestos This has created an atmosphere of confusion and emotional reaction versus straight fact The use of asbestos is varied in fact it has been used in over 3,600 products Many of these uses including roofing felt are considered safe for normal installation on the jobsite Asbestos felt is manufactured on multiple cylinder wet process papermaking type equipment The asbestos fiber is added 1 to the wet mix enclosed in its package The paper wrapper becomes part of the product This procedure eliminates the concern over free fiber in the manufacturing process The ingredients are then bound into sheet form with latex The dry felt is then run through a number of dips saturating it with hot asphalt The manufacturing process therefore encapsulates the asbestos into the product The fiber is virtually locked into and bound by the asphalt Of concern when using asbestos products are the application and eventual removal of the materials In 1983 studies of asbestos roofing applications were completed by the Research Division of the Asbestos Institute in Quebec Canada Collecting breathing zone samples and analyzing by means of Optical Phase Contrast Microscopy OPCM according to NIOSH P & CAM 239 determined that no asbestos fibers could be detected on any of the personal breathing zone air samples The con- clusion of these tests were in part The concentrations of asbestos fiber being below the analytical limits of detection of 2 the phase contrast microscopy method no health hazard to asbestos is existing Probably the most extreme test conditions as to dust levels is related to the tear study of asbestos roofing felt In 1985 a tear study was sponsored by the Joint Industry Steering Committee on Asbestos of the National Roofing Contractors Association Actual monitoring of dust levels were conducted by the Research Division of the Asbestos Institute Members of the committee included contractors labor industry and the National Roofing Contractors Association The Optical Phase Contrast Microscopy according to NIOSH methods was again used No wetting of the roof or special methods were used in removal The findings according to the study were in part No occupational health hazards may be attributed to airborne asbestos fibers in the course of this roofings demolishment because the concentrations of asbestos fiber are below the limit of applicability of the NIOSH method 7400. The mean results 3 per cubic centimeter for a permissable exposure level Dr. Irving Selikoff of Mt. Sinai a noted and well regarded expert in the area of asbestos related disease addressed an industry conference in 1977. His comments related to his study of 6,500 roofers It included every member of the Roofing Worker's Union as of January 1 1960. Out of 2,500 deaths not one case of asbestos mesothelioma was found Dr. Selikoff stated in part If there was enough asbestos exposure in built roofing to give a significant hazard due to asbestos I would have seen at least one mesothelioma Had there been any danger from the use of asbestos roofing felt there would have been evidence of such since its introduction in 1910 Asbestos roofing felt today does not enjoy the market share or growth it has in the past In 1985 the total U.S. market for inorganic roofing ply felt was 44,000,000 squares M a square being 100 square feet Asbestos felt held 250,000 squares By comparison this appears to be a very small and minor share of the market However asbestos felt occupies an 4 important position in the industry Asbestos felt has become a specialty product for particular uses in critical areas of roofing applications It is used almost exclusively in flashing applications on flat roofing Whereas the entire roof area may be covered by glass roofing felt the critical edges those areas where changes in elevation occur are still treated with asbestos Its direct competitor in this area glass felt flashing has many disadvantages and does not come close to having the performance characteristics of asbestos which include - outstanding weather resistance with no special surfacing - highly flexible in changes of elevation - compatible with all other systems - and most important no memory as does glass felt nor the propensity to pull away after attachment The only other system that it may compete with is that 5 of modified bitumen In this instance asbestos is favored due to the fact it is not applied with a gas fired torch which has in the past caused major fires in many of the applications where used The U.S. insurance industry is seriously considering no coverage to roofing contractors using torch methods It is also cost effective as compared to modified bitumen with a 10 15 cost reduction in asbestos In conclusion asbestos felt offers the U. S. roofing industry unique advantages not offered by alternate products in application safety utility service life and price Studies and comments by experts in the field show this product to be entirely safe in application use and removal It is not friable in nature and is locked into its matrix of asphalt and further locked into asphalt in application