Document 3GXom3YGY0eJaa5zxOwpn6Bx

UNION CARBIDE CORPORATION ROBINSON PLAZA II. ROUTE BO. PITTSBURGH. !=A 15305 METALS DIVISION ' To [Name) Division Location Area Copy co -- Mr. J. T. Kelly Dace October 20, 1983 UCC - Metals Division Danbury, CT originating Dept. Cal Idris Asbestos J- 1 Area RiS^lXMD D. F. Kapral G. M. L incoln, J. L. Myers OCT 2 4 jg83 Subject: Tfilccon 10/18/83 0.5 Fiber/cc TWA Impact on 1984 Sales T. P. Norris J. E. Walsh X ifgLLVj A report issued by Fred Smith on October 21 was intended to evaluate the impact on our asbestos sales if OSHA lowers the allowable Time Weighted Average (TWA) for asbestos emissions in the work place from the present standard of 2.0 fibers/cc to 0.5 fibers/cc. Fred's calculations were based on 1982 sales to customers for whom we have performed one or more dust counts in the past. His conclusion was that we could expect a 315% loss in sales if the more stringent regulations were promulgated. 1 have discussed Fred's report briefly in telephone conversations with you and Dan Kapral and indicated that I feel Fred's conclusions extremely prone to error because of several reasons. Realizing that any accurate assess ment of future events is haphazard, presented in the attached table is a comparison of what the sales department feels will result from an 0.5 fiber/cc TWA versus that calculated by Fred. Our differences in opinion are based primarily on the following premises: 1. In general you cannot assign a numerical risk value to a company's continuing use of asbestos based on previous dust monitoring results, i.e., a company will not use 1/3 or 2/3 as much asbestos in the future because of any new regulations. They will either use none, or as much as their business demands. This is especially true of such companies as Kentile (SG-103 and SG-104) and RCA Rubber (SG-200). In both cases we feel they will continue to use our asbestos even if lower emission standards are effected. 2. At least 18 plants cited in the report do not use our asbestos at this time, either because of their company policy or else because we will not sell to them. This does not cause a significant bias in Fred's results, but does point out the fact that our 1984 customer list contains a greater ratio of hard core asbestos users than in 1982. UCC 025463 * Mr. J. T. Kelly 2- - October 20, 1983 3. Because of the present government regulations, the adverse publicity, and the demands by certain customers for non-asbestos products, it Is recognized that almost all of our customers would not use asbestos If they could find a cost/effective replacement. However, it must also be recognized that asbestos (Chrysotlle) is unique, and most present day users have found that they cannot substitute for it without a sacrifice of some kind, either in cost, processing, or product quality. 4. Many of our customer, if it became absolutely necessary, could lower their asbestos dust emissions and probably comply with 0.5 fiber/cc standard. Although in many cases this should have been done by them before now, either by better work practices or engineering means, cost considerations have pre-empted significant improvements. 5. Although Fred assigned a risk factor of 1 for sales to Montello, i.e., a loss of 1/3 of our sales, it is the opinion of Jack Walsh and others that an 0.5 TWA will have no effect on our sales to this market. The main concern in the oil well drilling industry is to obtain emission values of 0.1 fibers/cc or less, so that medical examinations will not be required. Thus 0.5 TWA is not considered as a serious detraction. Because Fred's report was based on selective sales In 1982, it was necessary to take a certain amount of license in order to extrapolate his results for 1984 budgeted sales. However, the expected loss in sales of 35% correlates closely with the 31-5% reported in his original report. In summary, our 1984 projected sales will not be directly affected to any great extent by a lowering of the present TWA to 0.5 fibers/cc. More concern is over the additional adverse publicity which could result, and the possible action by other agencies, such as EPA and CPSC. In addition, even if a new standard is issued we could very well expect a compliance time period of 2-3 years during which the use of respirators would be allowed. GLD:vad Att. G. L. Dickson UCC 025464 198A CAL I DR IA ASBESTOS SALES Expected Loss (Tons) From Proposed Regulations Grade 1984 Budget SG-103 SG-104 SG-130 SG-200 SG-210 HPP HPO RG-100 RG-T10 RG-144 RG-244 UN 1V1S CSV SHUREL1 FT TELVIS 2,640 5,200 30 540 220 60 990 500 220 210 270 40 1,200 190 170 TOTAL TOTAL LOSS 12,480 - 1984 Expected^ (Calidria Sales) 2,640 5,200 0 540 150 60 700 500 100 100 200 40 1,200 190 170 11,790 6% 1984 Estima (F. L. Smi 1,770 3,500 30 360 100 60 350 500 70 100 260 30 800 130 110 (2) 8,170 35% (1) Developed from asbestos sales department input. (2) Based on risk factors taken from Fred Smith's report. % UCC 025465