Document 3a3w9Kkb3gjx3GXnmnj7wxoO
Asbestos Information Association ''North America
22 Eesi ty.r, Si'Ml New York. N. Y. 100^ 5 212-*63-337S
October 24, 1372
TO: A2A/KA Executive Comr.ittee
Gentlemen*
Attached is the first dr*ft of a proposed A2A/KA "Employee Safety * Health Guide* on asbestos. The purpose of the Guide, which would be printed in booklet form, is to inform asbestos industry employees of the basic facts about asbestoshealth and also about employer responsibilities under the
OSEA regulations.
The main reasons why I am proposing such a booklet at this time are as follows:
1 The 2TO is launching a program (the Mount Sinai seed*** in late Kov .obex is the first step) to i .form employees throughout the industry of the ialth hazards of asbestos and how to best use CSKA to assure compliance with the standards. There is little doubt that the ITO will paint a very black picture of the health situation and of the industry's supposed lack of concern f~>r its employees, and will encourage local unions to constantly search out even minor infractions of the regulations for reporting to C3HA, as well as to press for strict observance of all employee health rights granted under the law.
Xn my opinion, it is essential that we gat to our employees first with the facts about asbestos
health, and about oSHA, rather than to permit the 1TO to present its highly distorted,
anti-industry "information* unchallenged.
2.
PLAINTIFFS EXHIBIT
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One of the major arguments voiced by both Tony Mazzoehi and Dr. Selikoff at the Lyon conference for greater union participation in medical and other meetings on asbestos-health was that the industry wastakinfiLjjp active steps
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to inform its employees of the hazards of
Asbestos ana was, in fact, trying to beep these facts hidden iron its workers.
Thus, in principle, a booklet of this nature
would have the support of the 1UD and of Dr. Selikoff. It would also be an effective refutation of their charges that the industry
is doing nothing to inform its employees.
1. OSEA has on more than one occasion voiced its contention that industry should provide employees with as touch information as possible on occupational health hazards, and that OSKA
would look favorably on any industry that did so.
In my opinion, it would be a serious error on our part to continue to hold the belief that our employees are, for the most part, unaware of the asbestos-health problem and are not going to find out about it unless we tell them. 1 think we must face up to the fact that employees in all areas of the asbestos industry are becoming increasingly aware of the situation and are going to become better and better informed as the JVV end ether medical-labor informational programs get into full swing. The point is simple*. If we don't inform our '-<t;loyees, somebody else will:
X am fully aware that one f the major industry fears with regard to providing employees with facts on asbestos-health it that this would result in a great increase in workman's compensation claims. While there may be some validity in this argument, think for a moment how many claims there would be if the XDD and Dr. Selikoff were permitted to present their estimate of the health situation to employees without any refutation by the industry.
One of the major problems that can be anticipated in any industry sponsored informational program for employees is the attestion of credibility. Will employees believe what we tell
them? or will they consider the contents of the booklet to
be nothing but a pack of industry lies and misinformation? Because of this credibility problem, it is e&sential that the
booklet not be a propaganda piece, but it must be as factual and irrefutable es we can possibly sake it. For this reason,
for example, 2 have eliminated ell but a passing reference
to industry efforts in controlling dust levels and have instead concentrated on the industry's responsibilities to -its employees under CSKA. Hopefully, the employees will come to the conclusion
that if the industry is willing to tell them what the law requites the industry is, in fact, planning to obey the law.
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i As another example, I have avoided the subject of what is a safe dust level by emphasizing that the reduction of dust exposures to as low a level as is technically possible is universally accepted as the best way of preventing disease. To argue about dust levels would give the impression that the industry wants to do as little as possible, and is looking
t for excuses to avoid doing more.
\ To have this booklet be credible to the majority of workmen,
r it is essential that we avoid points of controversy with the XtTD and Dr. Selikof as much as possible# and also that it contain information of value and use to the employee.
D You will notice in the draft that considerable attention is paid to the use of finished asbestos-containing products. As we are all aware, there is much misinformation being
r circulated es to the safety of such products. This booklet
c. can# hopefully, also be used by cur customers to help allay the fears of their workers.
r Because the ITO-Mount Sinai seminar is a mere five weeks away, L 1 believe it is essential that vp proceed as rapidly as possible
with the production and distribution of this booklet. Of
C course, no member company has to make use of this booklet if, in its opinion, the disadvantages of using it outweigh the advantages. Nevertheless, for those companies that will
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find it useful, speed is essential. 1 would appreciate, therefore, receiving your comments on it as soon as possible.
Once the Executive Committee has agreed on a final draft, we
r: will then send it out to the member companies for final approval.
l Sincerely,
n
L
Matthew H. Swetonic L Executive Secretary
r Enclosure
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Introduction If you are an espleyo# engaged in the aining, manufacturing, or handling and fabrication of asbestos and asbostee-containing products, there are estain facta concerning the potential health hanard* of asbestos sad what to to about the that you should know*.
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The purpose of this booklet is to provide you with information on what theao hatarda are, whether your job is affected, what laws eadst to protect wertaeefl, a: 4 what you an do to protect your ova health and that af your fellow ecpieyees..
Health Tacts About Asbestos
.
It is a generally accepted fast that the inhalation sf ixeesciti quantities
of free asbestos fiber can Increase an employee's risk of developing certain
disease# of the lung, including asbestos!*, bronchogenic aneer and esotheliema.
Because it takes aaajr years for asbestos-related illness to absw op In an
individual, the disease being found today aaong long-term asbestos industry
espleyoeo is a result ef conditions that existed 20 or 0 years ago, at a tlae
vhas neither the aedlcal profession nor the Industry knew very much abeut the
health effects f asbestos or tha proper scans for their control.
Vbile there are difference# of opinion within the asdics! profession eoneeniap say aspects sf this problea, it is *uaiver*ally accepted that dust levels in the verkplaee should be kept as low as aedera technology out possibly achieve* At the present tins, the reduction ef dust levels is the only known aethod of preventing those diseases ssioag exposed vorkata* Experience has shown that when
dust levels are low, the ineide&ea of these diseases drops *^7*000184
It has tlM b*ea proven that heavy asbestos exposure greatly increases the
risk ef lung cancer fr ci^trette
kut that asbestos industry esrkaen
*hs 4* ** *k* cigarette* hare no greater risk ef lung eueir than the average
aan-en-thestreet whe dees not seeks*
le J*r Jeb Ha2ardsua7 ia a general rulsr seat ea^loyees engaged 1a the artnlng and silling of ubeites ** tlber# Is the aaaufacturing ef asbestos-containing products will be exposed te 9 quantity ef airborne asbeates fiber in their Jsbs. In properly controlled plant* and sinea* these levels will be extraaely lev* In improperly er oncostrelied operations* the levels say be dangerously high* Kest aarufacturiag plants in tha industry are nev er aeon will be properly centrolled*
She installation er application ef pest finished aabe*tea-containing produeta will pet produce dust levels high enough to be ef concern* In products such aa vinyl-asbestos floor tile and asbestea-cecent sheets and pipe* the asbestos la solidly locked into the product with ceaent* plastic er ether binders In such a tanner that the fiber is not easily released during narxal handling and application*
Sate asbestos-containing products*, however, each as nasatnreted textile# and
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eat asbestos insulations, can release potentially hazardous* asounta ef aabeates
during handling er fabrication. She tear-oat er reseval ef eld asbestos-containing
Inaulatlena can likewise be a very dusty eperation* 2hee products uat, thsrefsrer
be bandied with caution using approved awthoda ef dust auppresalon and control
to sdnisdse the generation ef airborne fiber* fortunatelyenly a very aaall
percentage ef the asbestos-containing products produced in the felted States each
year are capable ef releasing elseable quantities ef dust during handling er
apjaiemon.
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It yu are unsure whether the product ywv art using Iff capable at producing
potentially hanardeue amounts if Mbeftu dust, chock the oarton tr bag
in which the product was shipped* Manufacturers are required by law to plica
a caution label & all asbestos-containing products that readily release
Mjb levels ef fiber during handling or application* The label baa been placed
there for your protection look for it it you are t&suro*
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Zf yea do rot work direetly with asbestos or aabestos-eoateinirg products* but
work lb eloso preadsity to thoso whs do, orach ass & a construction alto where
saboetes-centaifiisg insulations are being allied* you should chock to dsteniae
if these products are Wing handled properly* If they tr*,. it is highly unlikely
that you will be exposed to potentially unsafe levels of asbestos* Xf proper
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precautions are net being taken by other workmen on the job site, this should
be reported to your explorer or union representative*
Regulations On Asbestos
On fane 7r 2972, the Occupational Safety and Health Adxiaiatratisn (OSHA) of
the T<ed States Department of labor issued occupational standard* for exposure
to asbestos dust* These standards have sue aajar purpose -- to protoet you fres
exposure to potentially hazardous snouat* of asbestsa dust, in your work** Tbs
asbestos standards, as they are coaaenly called, contain cany detailed
requirements, however, the basic obligations placed on the scpleyer under-the
standard* can be mamti vp as follows*
lm She eoployor shall %dntaln a healthy workplace by waking*
sure that ns osplsyee is exposed ts concentration* of sirborue asbestos fiber in excess of established Visits.^l'- ^ OQOlSS
The current OSHA Unit for exposure to sabeotoe is 5 fibers, fie microns in length or longer, per cubic centineser Coe) of sir ae averaged over sn &-heur workday* At no tine nay an esployoe'a exposure exceed 10 fibers per ce* Xar<197o* the b-hour average is scheduled to be reduced to twe fibers perreas* A sheres la approximately 1/25,000th of sn ineb, and a eeubic centimeter ia appro^n*t#ly
Z, kbere exposure Halts are exceeded the espleyw* shall be notified
in writing of the situation by his espleyer and shell be infon* d
of the eerreetive aeasures being undertaken to reduce bis expose
to a safe level*
3* khile emctlri etfvei are being instituted# the erpleyee ahull
be protected by ether aeus sash as b7 the wearing of *n approved a
rospimtor provided by hi* employee or by shift rotation.
4, Engineering controls and the institution of safe work practices
re the approved Methods of correction.
5* She use of respirator* or shift rotation to achieve control is
set permitted except <*) during the tine necessary to install
engineering controls or to institute safe verb practices*. (b) Is
sitatties* vhive such control* or practices are sot technically
feasible, ar <c) i* esergenelea.
6. Ke employee shall be assigned to a task requiring the use of a
respirator if hi* west recent yearly sedictl otasiaatlon indicates
that ha would be dahle to fwtisa properly while wearing sne# or
If the wearing of a respirator would hazard the cpleyee's health
r safety or that of another verfcaaa & the job*
? Special protective clothing, change roeas and separate clothes
Xsefcenr shall be provided for espleyees is nrttiA situations*.
8 Personal and earlronaeatal Monitoring of workplace air shall be
ooadeeted by the stepleyer to assure that the standards are being
set* Employee* shall have access to the results of the Monitoring
sf their job*
9* Varying signs shall bo poetsd la areas etc re the dust level is In
xcess of the standard.
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10. Gotten UWU shall be pieced e*
osheateo-ooatai&iag
products that are likely u release free as best#* fiber la excess
of the standard during fcssdliiig* application or fabrication*
11* 5h eopieytr skill provide yearly oedioal t**n*U*a* for asyloyeaiB exposed to cenoentreties* ef asteatea duet* Pre-espleyvext sad
termination sedical exam* ue also required*
12* At hia request, as employee*# wdical records can be wade available
to hie fasily physician*
While the entire set of asbestos regulation* covers nearly 4)5 large pages ef flat print i the Twelve Key Folate listed abeve are the west important a* far. ss yeov the aspleyee, is concerned* Standing behind the working san, ready ta enforce these regulations, is the Occupational Safety sad Health Mnlnistrntieo, with Inspectors sad effloes all scroes the cotetry* Zf the standard* are not belag wd, *ay employee has the right to cosplain to 05HA sad request a government: inspection teas to lav*litigate the situation* Esplcyemwhe fail to sbey the regulations are sublet t hoary fines. It is ia your beat iatereet t faun* year righto under the law sad whet obligation* year employer has toward you* The Twelve Key Points listed above should help*.
Vhat Css I So?
Industrial safety and health eon sever be only one person's responsibility* Both
saployrr &&
wsr* together to provide a safe and healthy working
BTironjwat* 2a certain segment* of the construction industry, for onsple, rn
detailed work practices will have to be instituted to assure cetpUnne* with
the regulations. M sa owployoe, It will be year doty to fellow theso work
practices at all tlaea, aad not taka shart cate that may endanger your own health
and that of other weHove on the job as: well as possibly hubjest your espleyerr
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U la BMMUI.7 fiAt* Far uitber
if 7n Mr a petntl4 kiii^ that
T*w employer w; tare overlooked* point It out te hie far correction* Onij if
ha oenttaeeuely ignores obviously hazardous situations ar refuses to eanaeet
the* should you report the violation to G5HA. Reieiber, eoaplianor with th<
rtfulatiaaa trill be ertrenely difficult and very expensive la many aegaeste at
the industry* Z& the interest if saving iebs as veil aa assuring a healthy-'
workplace* industry and labor aust work together to sole* their watual probleas.
Ashestea a** 0& page 2 of this booklet* It was pointed out that saeVdng cigarette# greatly increase* the risk of lung cancer anosg espleyeae exposed te excessive *astitles af asbeetee dust. Statistics ahov that la&g ters* heavily exposed asbestos insulation workers vh# ssofce cigarettes hare a $2 tins greater risk of developing iung cancer than their fella* verkers whe do not saeke* In fast* if you do not seeke cigarettes* ares If you hare bees exposed to excessive concentrations af aabestas dust far 20 ar sere year*,. you have no greeter chance af getting long cancer than the average n-on-the-street who does not sseke*
She advlca of cedieal specialists on this natter Is staples If yea work with . asbestos and seeks cigarettes, Haiti If you work with asbestos and 4a not sacks< don't start*
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Isssz Asbestos can bs a has*rdeu* substanea if Inhaled in sufficient chastities* There 4 la a reeog&lxad need to keep dust levels as lew a*-possible lor exposed verkers. tEhe asbestos industry Is working hard to achieve control.. The vest ajerity ef finished asbestea^eontaiRing'products are net basardea* to use or handle* The Occupational Safety and Health Adsdniatratien has issued regulation* to protect
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Ajmrtets vor>a*fi lr*a crposui* to h**>7 eeBeaCmio sf **betoa ftwt. T valet tbcii regulation* verk preptrly, the se*j*mio& of both i?lyer *pley*e 1 essential* labestes verkem *bial sot rale* ci^uttUir
for Additional or Kora Betailei Xfcforaatioa Or For Additional Copies f Shis Booklet
Contact
Tht Asbestos Information Aa#cintiV*erth Aaeria* Bait* 1611
22 ut Aotb Street *ew Tor*, H.T. 10016
psoras (212) 689-3378
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