Document 44D8LNBpnyZ50XEXXwDjBzKOe
AWH6-2001 13:13
Stuart CalKcll John H Skaggs
Mary McQui.n
Shirfey A Staggs
FWM-STUART CALVELL
*3043443584
T-357 P 001/0D8 F-785
THE lAV orri06 or
&TUAQT CALWELL. pllc
105 Capitol Street Suite 607
Post Office Box 113 Charleston, West Virginia 25321
Telephone: (304) 343-4323 FAX; (304) 344-368-
Toll Free: 1 800-876-5529 Email: stuartca)well@cal\vel law.com
David H. Cuiigcr John H. Koiak
D Chiiiiophn Hrdgn
Abu adiniuod in VA
facsimile cover,sheet
DATE:
go01.
TO: FROM:
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CP
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A total of______ _____________ pages, excluding the ccver sheet, is being transmitted. If you are having difficulties with reception, please call telephoie number (304)-343 4323 and ask for
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AUG-16-2001 13:13
=?O^STUART CAU*Ell
!
*3043443684
T-357 P 002/008 F-785
11 v <
coEpasjvrrcr:
%fV<-J Messrs:
O.Vif#*
U,T
O. Benjamin T. F. Frangos 3. E. Godard ,r. L. Myeri / .f, A. RiddU\/
J. Setter r. T. Sinclair f. R. Stickney
S. Young
Bit
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ArwfoghH"
r.bf.rf
in nu ttfwt UV* rcu. Mh rcH ;ai7
April 3, 1969 Medical Department
A ibestoi -----------------
U.-^VID
APR 7 '==9
UXC. o*ia t. nAmc*
lentlemen:
Both because of changes in regulations and availability of
lata developed after the issuance of our report in 1964, Dr. Dernehl
ind have revised the asbestos memorandum. A copy of the revision
ii enclosed.
'
The major changes are the decrease in the Threshold Limit .'slue from S million particles per cubic foot of air to 2 million ^articles per cubic foot of air. (*rhcre Is also a provision for mothsr method of counting but it does not appear applicable to our ihort fiber asbestos.) We brisfl} discuss mssothsliomas, but data i too scanty as yet for a definite policy to be established. It is rorth mentioning chat the Americtn Conference of Governmental industrial Hygienists considersd in 1968 a requirement that airline respirators be required for all contact with crocidolitt asbestos. The resolution did not pass, but may come up again in future meetings.
Any questions or comments will be welcome.
Very truly yours.
vyZ'P
ICS L:lk Enclosure
0 3 1 3 '
705031
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=50W-STUAPT CAlhEll
-3:43443834
'-357 P 003/0C3 F-735
;^22S?OS TCXIC0LC3? S2?C"7
Ir has been known for ycirs that some persona
Perkin,; la Asbestos production were prone to develop a
dUatl
lur.3 disease. Ir. time, tnis condition becar.e
-:nov:r. jis asbestos is and was related to exposure to high
cor.oea-:rations of asbestos dust. With further experience, it
was fot:ad that men could work with asbestos without development
cf lunj; disease If dust concentrations were kept below a
certain level.
It has been generally accepted that a worker will not
iavelo; asbestosis if he is exposed to no more than 5 million
panic: ss per cubic foot of air, evsn if this exposure ecn-
tir.uos ?or his entire working lifetime. Although no cases of
asbc^tcsis are known to have occurrsd when exposures have
been =* Lntlined at or below this level, the ACGIH (which sets
tha threshold limit value (TLV) in :he U. S. A.) has
indisatd they intend to lower the 'TLV for asbestos to
2 rtilli >n particles per cubic foot :Ln an effort to increase _
the sal-sty factor incorporated in the limit. The U. S.
departs-rat of Labor has already Issued a regulation under
the v:al ih-Ktaly Act placing the TLV for asbestos at 2
million particles per cubic foot for public contracts in
which they have Jurisdiction. This concentration of dust
is gene 'ally not visible in the average work area unless a
AU3 13-
705032
ADG-I6-2001 13:14
FROH-STUART CALVELL
*3043443684
T-357 P 004/008 F-785
bear. of light causing a Tyndall effect is present. Vs.illy the - s* concentration must bs fro a 3-10 million particles per cwibc foot (>t?FCF ) before Its preser.ee it visible in average lighting conditions.
>:averal years ago, it was reported that there was an ir.sra.. ae in the incidence of cancerous tumors, especially of t.-.s lung, associated with asbestosis. Recently there have lean reports of some cancers occurring in individuals expos r. to asbestos dust, but who have not developed clinical ascco :ssis. It is believed by most authorities that these cases have been associated with exposures significantly exete: ir.g the Threshold &iit Value.
f type of cancer named mesothelioma, has been noted to os as:delated with asbestos exposure in recent years. These tumor;f while rather few in number to date, may occur in individuals with histories-of only slight exposures, and tr.it at much as twenty to forty years earlier. There is conai:.arable evidence that crociddite is most frequently associated with mesotheliomas. ?rca the data available it appears that the 7LV of 5 KPPCP 1: not low enough to protect against mesothelioma, and it is quite possible that 2 K??C? is no'.., either. Research on the problem continues,
Control of asbestos dust exposure is therefore necessary. The control methods are the standi;rd ones applicable to a variety of dusty operations.They :.nclude closed flow systems,
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*" *
AUG-16-2001 13:14
FRCM-STIJART CAL&ELL
*3043443684
7-357 P 005/008 F-783
-3-
wct p ocosses whera possible, and idequatc exhaust ventilation ..hero openings in "he system are necessary. Pelletizins is somet hues used to improve the handLins characteristics of other :.se dusty materials. Vfnere satisfactory containment to st.:y within the Threshold Limit Value is Impractical or impossible, efficient and reliable respirators are available for the protection of the employee. A program of environmental monitoring is higoly desirable to determine that Threshold Limit Values are r.oc being exceeded. In paper nz.ruf3ituring, it would be desirable to know the dust conser.tr;.tions where the asbestos is lumped from bags into the . pulp blurry. Concentrations should also be determined where dus: 1:::; occurs in finishing products. While initial dust determinations should be made at frequent intervals, once the level r.ts been established as satisfactory, the frequency may b; extended to occasional tests to assure continuation of a satisfactory condition.
? re-employment and periodic piiysical examination of workers are desirable. These should include chest X-rays to insure that the worker has no chest condition prior to work with asbestos and to determine that no lung changes ama rtisuiting from work with asbestos.
U is believed that the addition of asbestos at the preps:;2d levels during the manufacture of paper products would :e harmless to the consumer. Total dusting would
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70503
AUG-16-2001 13:14 -
*
FWIWTUART CAlHEll
*3043443584
T-357 P 006/008 F-785
have :o :i "411 1r. excess of any levels acceptable to the
cons*
Tor the asbestos* ccr.ee-; rations to a-preaeh the
T:-.ras.-.c:.i Li"i: Value. conclusion, while aobestos just in excess of the
Throshe i liroit Value is potentially hamful, as are Easy other c. .w a encountered in industry, it is as readily
control oi as other such dusts ar.d Jx can be used safely with appropriate precautions.
Industrial Medicine And Toxicology Eepartr.ent Union Carbide Corporation
A U 3 `,4 70503a
AUG-16-2001 13:15
FROM-STIJART CAL&ELL
*3043443684
LiViw
--- Uw.- wr.i
170 -*aAK AVtNUC. KC.W C*K. .X.V. IS>17
-357 P 007/003 F-783
AS3ESTOS TOXICOLOCV REPORT
It has been known for many years chae scot ptrsons working in asbestosi production vara prono to develop a disabling lung disease. In time, cl Is condition became known at asbettosit and was related to oeposurt so high :or.;encracions of asbestos dust, With further experience, it wet found cl it men could work with asbestos without development of lung disease if dust :oncentrcions were kept below a certain level. Ie is now gen erally iiicepted that a nan can work a 40-hour weak for a lifetime without develop) ig asbestosis if the asbestos dust particle count is kept at or below 5 liliion partlclet per cubic foot cf air. This dust concentration of 5 nil lion particles per cubic foot of air ie the Threshold Limit Value for esbiitoi, and no casts of ssbestosis irs known to have occurred when exposuri i have been maintained at or .below this level, despite large-scale utilisat Ion (now approaching one million tons per year in the U.S.A.). This cor jsntration of dust is generally net visible in the average work area uni iss a beam of light causing a Tyndall efface Is present. Usually the duel concentration must be from 8*10 Billion particles par cubic foot before J; presence is visible in average lighting condiciona.
Several years ago, it waa reported that there was an inereaea in the incj lance of cancerous tumors, especially of the lung, associated with asbescoils. Recently thsre have been reports of some cancers occurring in individiills exposed to asbestos dust, but who have not developed clinical ssbescoils. Zt is believed by moat authorities thee these cases have been * iciated with exposures significantly exceeding the Threshold Limit Value, i major manufacturer of asbestos products who also mines asbestos has not >ean able to show an increase in eanctrous growths in man working where di it concentrations were maintained at the Threshold Limit Value.
Control of asbestos dust exposure is therefore necessary. The
control aechoda are the standard ones applicable to a variety of dusty
operatic* ]* They include closed flow systems, wet processes where possible,
t.and ade< jate exhtuac ventilation where openings in the ayacam are
necessai
Pelletising is sometimes used to improve the handling character
istics oE otherwise dusty materials. Where satisfactory containment to stay
within >;ae Threshold Limit Valus Is impractical or impossible, efficient end
reliable respirators are available for cha protection of the employee. A
program jf environmental monitoring is highly desirable to determine that Threshold Limit Values are not being exceeded. In paper manufacturing, it
would bs. desirable to know the dust coneei.cretions where the esbeatos is
dumped j'eoca bags into the pulp slurry. Cencentrations should also be
determined where dusting occurs in finishing products. While initial dust
decermi;tions should he made at frequent intervals, once the level has
been as ubiished es satisfactory, the frequency may be extended to oecasioiiii tests to assure continuation of a satisfactory condition.
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AUG-16-2001 13:15
FRCM-STIJART CAL&ELL
*3043443684
7-357 P 008/008 F-785
Pr-mployment and periodic physical examination* of workers art dasirabli. These should include chest X-rnyi to insure that the worker has no c.'siit condition prior Co work with .ubescoa and co determine Chet no lung changes are resulting from work with asbestos.
lc is believed ehae the addlelon of asbestos at the proposed levels during the manufacture of paper products would be harmless to cha consumer. Total dusting would have to be sail in excesi of any lava la acceptab n to cha consumer for cha asbastoi concentration to approach eha Threshold Limit Value.
Zn conclusion, while asbestos dmc in excess of the Threshold Limit Va! je is pocancially harmful, as are many other dusts encountered in Indusi ry, it is as readily controlled ei other such dusts end it can be used nifely with appropriate precautions.
Carl 0. Darnehl, M. D. Director of Toxicology
L. S. Lane, M. D. Assistant Director of Toxicology
705045