Document 3e69wxMVxeExm2wX7DYVDrE73

/ N. 0. Pehrson, Esq,, Turner Brothers Asbestos Co. Ltd., Hochdalt. HCS JLC/XMW Dear ifr. Pehrson, 9th Noveaber 1950. Draft Shipbuilding* Rerulatlons Consequent oa ay discussion of this subject at Washington last week and with you this weals, I anolooe herewith a copy of a draft letter to the Factory Department of the Ministry of Labour which I hare prepared. You will appreciate that this is only a preliminary draft intended largely to serve as a basis for discussion; it is clear that the fora of the letter will require careful consideration both by / JVv.R.Ltd. and N.I.Co.Ltd. and I anticipate that substantial alterations * to th& draft will be necessary. I am sending to Mr. Soothill another copy of the draft letter together with a copy of this letter to you and eo far as N'.I.Co .ltd are concerned, X hare also written to Mr, Shaw with another cooy of the draft letter and hare sont copies to Mr. Hanson and Mr. Wilson. The two major points appear to be the rital necessity of excluding Finished Articles from the operation of these Regulations so far as asbestos is concerned, and aeoondly, tha equally important question with regard to the uoo of respirators by others worhinc, in the "vicinity'*. it I: II /( J After 2 hare reoeirad suggestions from the Directors to whoa the draft latter la now being sent, X will sake appropriate . alterations to the draft, and it may be that a fleeting between us and V Mr. Shaw will prore desirable and would probably save time and correspondence. - Tours faithfully, Xnc. Seoratary fffffff# c/fi \ The Ministry of Labour and National Service, Factory Department, St. James's Square, London, S.V/,1. Lear Sirs, Draft Regulations for Shipbuilding and Ship-repairing ' A copy of tho above draft Regulations has re'ent^y seen sent to us by our Subsidiary Company, Vevalls Insulation Co. Ltd- of Ucshtngton Station, Co. Durham, they beLns concerned with the references contained thGrein to asbestos, since they carry cr. a substantia}, insulation contracting business in conna -.ticn with ahipbuiidinr, and ship-repairing. In addition, another Subsidiary Company of Turner <3: Ldwa-.t Ltd., is concerned, nanoly J. >/, Cohorts Ltd, of ;iid.-.ur;d -tries, Armiey, Leeds, that Company boing the owners of certain patents undor which the Roberta Asbestos Lpray ?rc:osc is operated: Newalls Insulation Co. Ltd- hold o Liconou from J, V/, Roberta Ltd. ( - in respect of the use cf that Process in connection with ship building aria ship-ropairing. f)i draft MoiiUJ.atii.nl suggest that statsminte should be sent to the Ministry, indicating briefly and provisionally what points on the draft Regulations it is desired to discuss, and accordingly I have been asked to put the following points foiward for consideration by the Department and for later discussion, 1. It may first be of advantage to refer to the circular letter sent out by the Ministry in August 1945 under the I' .. 2 - heading of "Asbestos Insulation aboard Ships", to which In fact a lengthy reply was sent to the Chief Inspector of Factories by Turner & Ilcwall Ltd. on 4th October 1945- 3u*h reply shoved 'inter alia) that no difficulty arose so far we were concerned in the case of the six point* mentioned in :hi circular letter of August 1945, except point 3 ;or..;erning the use of respirators. As regards that point, our reply indisntod that the suggestion that workmen engaged in fitting or removing any dry insulation material containing asbestos on board ship <as suggested in point 3 of the circular letter' was in our vie*'' quite unnecessary and Inappropriate, and that If any such action wore ir.posod in that manner it would in sffo:t a very wide extension to the ..sbestosls Regulations, A3 the latter na'.a always applied-in general to manufacturing processes only and have not in any way applied to finished goods. Moreover, our reply stated that it was significant that our experience in the past had shewn that no cases wf asbestoaia have arisen amongst employees handling and applying finished products; that, I understand, is still the case. We aro concerned only with those portions of tho draft Regulations which apply to the use or application of asbestos, namely tho definition of asbestos in Regulation 3 and tha provisions of Regulations 70 and 71 a* to the use of respirators and the employment of young persons* The definition of asbestos in Regulation 3 states that asbestos means "any fibrous silicate mineral and any admixture containing any such mineral", and vo would like tc . 00 /<? Oi? /0 5 ( S( -3 - be allowed to submit that such definition is certainly ambiguous and might be read as having an extremely wide application. For the reasons mentioned in our letter c 4th October 19-1? and referred to also in this letter, we that the definition of asbestos should be limited to the and application of the fibre itself (or any admixture thei in its raw and dry unmanufactured state, and that to preve. misunderstanding the definition should show that nanufactui goods are completely excluded from the definition- We fee. it likely that it was not the Department's intention that manufactured goods should fall within the definition, but we think that the position should be made clear- Nova'is Insulation. Co. Ltd. (in addition to operating the Spray Process) apply on board ship a large range of manufactured insulating materials such qs Sections and Slabs composed of magnesia and/or asbestos; in many cases these insulation products are covered in cotton canvas or scrim cloth, in others they are mixed with cement, and in all these cases there in no asbestos dust and no possibility of risk. Moreover, a large proportion of the products appliod by Newalls insulation Co- ltd. are what are known as t:85 Magnet Products", tho asbestos content being the remaining 15% only. As a basis for discussion we put forward for consideration by the Department the following revised definition - "Asbestos" means any magnesium silicate mineral in its raw and dry unmanufactured -4 - containing any such mineral, this definition not including therefore any manufactured products or plastic composed wholly or partly of asbestos" 3- As regards Regulation 70 dealing with respirators, the wording of paragraph (a) would be, in our view, much too wide 'unless the definition of asbestos is United so as to exclude manufactured products* We are under the impression that in general the i references to asbestos included in the draft Regulations have been included because of the wide-spread use of the Asbestos Spray Process aboard ship, and that such references ar^ therefore intended to be directed mainly to the uso of that PrccohSo No suggestion has ever been made to us before that respirators should bo worn in connection with tho handling or application of the finished articles; on that basis every plumber for instance installing Magnesia Insulation Sections ( anywhere in this country should wear a respirator^ Before the Asbestosis Regulations case into effect in i?3l, we were similarly given the opportunity of salting representations to the Hose Office as regards the wording thereof, and certain suggestions wo then made were accepted having the effect of excluding all manufactured products from the operation of those Regulations, and confining the latter in effect to'asbestos Ilia in its dry and unmanufactured state. The incidence of asbestosis since 1931 shows that such limitation of the Regulations was perfectly appropriate, as asbestosis cases within this organisation since 1931 h*ve -5- in general occurred amongst employees handling dry asbestos fibre as such and not amongst employees handling finished goods made wholly or partly of asbestos* As regards the Spray Process itself, our sjjray operators have been provided with respirators for a number of years at the request of the Department, and I am informed that it is still a fact that no asbest-osls cases have occurred amongst them, although the Process has been in use extensively for seme 20 years and has been operated to an increasing extent, particularly during and since the War. the Spray Process has been very significantly improved during the last few years through the invention (patented by J. V. Hoborts ltd.) of what is lenown as the "Drum Damping Process" whereby the asbestos fibre is damped in drum before the mixture is placed in the Huberts Spray Machine. this invention has reduced th% dust in the atmosphere so substantially that the Spray Process can for instance now be operated by T, V. Roberts ltd. in railway carriage works alongside newly painted railway coaches whose paint Is still sticky- This point Is mentioned in relation to the word "vicinity11 in paragraph (c) of draft Regulation 70. That word is not dofined in tho Regulations and we would like to submit that the phrase "immediate vicinity" should be used, whatever risk there may be from the Spray Process can clearly only exist <if at all) in the immediate vioinity of the work. Proa the experience gained by J. W. Roberta Ltd. and Hcwalla 6- Insulation Co* Ltd. over a lengthy period, the risk would certainly appear to be slight, if not negligible, and this opinion is supported by the complete absence of any asbestosis oases amongst the hundreds of spray operatives who have teen concerned. Ir. -ase our lottor of 4th O'-tctor 194? mentioned aoev* is not available to you, I enclose a copy of it herewith, ("' we would be glad to accept the invitation contained in the I* re face to the draft Regulation* as to discussing the post tic:: personally with representatives of the Department at any mutually convenient date- . Yours faithfully, for TURHER ft IHh.'ALL LiMToD, ^ Secretary-