Document 3N545141KqYXJqBLDYv41dpLa

FILE NAME: Cummins Engine Co (CEC) DATE: 1980 Apr 17 DOC#: CEC005 DOCUMENT DESCRIPTION: Letter DEPART' INT O F HEALTH. EDUCATION./ 'JD W ELFARE PUDUC HEALTH SERVICE . CENTER FOR 'JtSEASE CONTROL NATIONALSI5NA6SF0TE0ITTYFUITSAEHNEFOROHSRELOAACLNCTEHUPATIONAL ROCKVILLE. MARYLAND-20BS7 Dr. Eula Bingham Assistant Secretary for Occupational Safety and Health D.S. Department of Labor 200 Constitution Avenue, N.W. Washington, D.C. 20210 Dear Dr. Bingham: APR | 7 1930 . The Rational Institute for Occupational Safety and Health (H1SH) recommends that the Occupational Safety and Health Administration'(CSKA) adopt a safer standard for uorker exposure to asbestos. The new ' standard would eliminate all exposure from new non-essential uses and . define a permissible limit for other exposure at th lowest level accurately measurable by optical microscopy (100,000 fibers per cubic meter, of air). Tor the last 6 months a group of scientists under the leadership of Mr.":' ` Richard Lemen has been reviewing Information on asbestos made available since the 1976 NIOSH criteria document.was transmitted to OSHAi The group, reaffirmed that, exposure levels below the current standard of 2 million fibers per cubic meter of air-- and below the 1976 recommendation o f 100,000 fibers per cubic meter oE air-- cause several types of cancer and other lung diseases. For this reason, the group concluded tllere is no safe level of asbestos ..exposure and that asbestos should be introduced into the- human environment only if no suitable substitute exists. In ocher words, good occupational health practice under the. Occupational Safety and' Health Act of 1970 requires eliminating any avoidable worker exposure to asbestos. When exposure cannot be eliminated it must be controlled to the lowest level possible.. To further understand the problem of removing all asbestos from the work environment, N10SH will undertake additional studies! 4 . . 1. We will examine the life cycle of asbestos, from mining to fabrication, use, and disposal.- This work will identify all. points where workers may be exposed to asbestos and-simplify enforcement of the new standard. 2 ; We will produce an inventory of all asbestos products likely .to reach the .work, environment. This inventory, along with the life cycle study, will help, quantify,the scope of efforts required to eliminate asbestos exposure. CUMMINS - 00177 CUMMINS003719 Page 2 - O.' Euln Bingham .3. U'e will establish a continuing review of the development of asle.M.o substitutes. This should protect workers by encouraging tepid . elimination of asbestos uses. - 4. Ve will.review laboratory facilities available for accurately analyzing asbestos since any new standard will require, increased analytical capability. The asbestos situation in the United States is grave enough to. warranc immediate action. Between 8 and 11 million workers have already been exposed to asbestos since World War II, Tens of thousands of cancer deaths each year are attributable to asbestos. Much of the asbestos that caused these deaths-remains with us today and continues to threaten the health of workers. Unless we move immediately to significantly reduce new applications of asbestosj we risk leaving behind an additional legacy of disease and death. Promulgating a new asbestos standard, based on the Work Croup's.. recommendations, would significantly contribute to preventing disease and,loss of life from future asbestos exposure. . Sincerely yours, Anthony Robbins, M.D. .Director CUMMINS-00178 CUMMINS003720