Document 4J4ZOXL5y8LrmkNrvK7OJnxbR

{ March 13, 1972 Pr a ntatIon n Pr posed Standard for Exposure to Aab at a Duat on behalf of the Aabeatos Textile Inatltute and lta member companies. Mr. Arthur M. Goldberg Hearing Examiner U. S. Department of Labor Office of the Under Secretary Washington, D. C. 20210 Re: O CO Hearing on Proposed Standard 2 For Exposure To Asbestos Dust, . Beginning on March 14, 1972 Dear Mr. Goldberg: My name is Alex Kuzmuk. I am a member of the Board of Governor^-; of the Asbestos Textile Institute. C '-u. m to'-; I am here today to officially represent and state the position *-- O of the Asbestos Textile Institute and its member companies. C-l We are in opposition to the proposed asbestos dust standards as*V published in the FEDERAL REGISTER, January 12, 1972. We are also opposed to recommendations proposed in the NIOSH-criteria package, and by the Asbestos Advisory Committee. / The asbestos textile industry, which this association represents, . includes over 4000 job opportunities in manufacturing, plus approximately 35,000 job opportunities in related product fabri cation and sales. The gross business volume for manufacturing al ne is over $d0_million per year. The gross volume for related fabrication and sales is, therefore, many times this amount. Although this is not the largest segment of the asbestos industry. it is a very important BY PPG INDUSTRIES, INC. ne. Our product lines include the manu| BB 0023007 | ( 4301 ') Mr. Arthur M. Goldberg Asbestos Hearing March 13, 1972 Pag 2 THic DOCUMENT WAS NOT A RECORD OF PPG INDUSTRIES, INC. DID NOT COME FROM j-pg f!LES AND CANNOT BE AUTHENTICATED BY PPG INDUSTRIES, INC. facture of safety garments, insulations, clutch facings, brake O cr :!:/ t'---i... linings, paper dryer felts, mechanical packings and gaskets, laminated plastics, and many other commodities essential to r C today's technological progress. In many instances, there"are < no known substitutes for asbestos textile materials. Subsequent to the enactment of the Occupational Safety and L ^ Health Act, the threshold limit value for asbestos dust was reduced from 5 million particles per cubic foot of air to 12 fibres per milliliter, 5 microns or greater in length. We, in the asbestos textile industry, made every possible effort to meet the 12 fibre threshold limit value by re-engineering dust hoods and dust collection equipment on cards, spinners, looms, and many other types of equipment. In addition; many of us initiated wet weaving and made extensive additional changes in processes and materials. When the further .reduction to the threshold limit value for asbestos dust was published on December 7, 1971, we began all over again to study plans for revising quipment, processes, and materials, for which we had just spent thousands of dollars to install to meet the 12 fibre level. Many of us have not, and cannot, reduce our dust levels to the . emergency and proposed 5 fibre threshold limit value. 002300tM If engineering to a 5 fibre level were feasible on the complex types of machinery and equipment used in the textile industry, 4302 the cost f implementsti n w uld mak it extremely doubtful that this industry could survive economically. We are presently being pressed t the wall by our competitors. The cost of a Mr. Arthur M. Asbestos Hear! March 13, 1972 Page 3 o ro -- -'I c;: ..4 program to meet the proposed asbestos dust standards could be the determining factor for removing American-made asbestos textiles from the market place. The competition to Which X refer will not be required to make extensive capital investments to change processes, provide *'proteorfatme^lothing, provide medical examinations, and monit ring. This competition is primarily from foreign imports. I, * therefore, take this opportunity to ask this Federal agency whether it will take the responsibility of recommending equitable tariffs to prevent this economic disaster, if the proposed Asbestos Dust Standards become effective. Beyond the proposed asbestos dust standards published in the January 12. 1972 FEDERAL REGISTER* there are recommendations by the Rational Institute of Occupational Safety and Health, and the Asbestos Advisory Conualttee. These recommend further reduc- ti n of the asbestos dust threshold limit value to 2 fibres per milliliter, plus many additional requirements concerning respirator equipment, protective clothing, monitoring, and thers. j bb'00 2300 9^ I With the problems we are encountering in attempting to reach the present Eaergency Asbestos Standard, it is unrealistic to even consider the feasibility of a 2 fibre standard. I would like to point out that Mr. Clifford L. Sheekler, chairman of the Asbestos Yextil Institute Environmental Health Committee, took the initiative in 1964 to request Dr. Lewis Cralley of the Mr. Arthur M. Goldb rg Asbestos Bearing March 13, 1972 PW 4 United States Public Health THIS DOCUMENT WAS NOT A RECORD OF PPG INDUSTRIES, INC. DID NOT COME FROM IT'S FILES AND CANNOT BE AUTHENTICATED BY PPG INDUSTRIES, INC. Service to conduct an epidemiol gical study of our asbestos textile industry. We recognized then that a potential health problem existed and, therefore, we wanted expert advice and assistance to help us solve it. We have neither received the advice nor the assistance which we had hoped for. We opened our plants to the United States Public Health Service personnel for environmental studies, review of our records, and physical examinations of our people. Our member companies urged employee participation in the study, and a substantial represent ative group of workers were involved. We continually requested the United States Public Health Service to increase their efforts and provide interim progress reports. ) mil '~ --BB~00230^!L*i The Publie Health Service Asbestos Study of which I speak has n t been completed. A recent report, which is a primary fact r in the recommendations by HXOSH and the Advisory Committee, was based on this incomplete study. The information provided in the report was based on opinion and speculation, rather than fact. Bad the United States Public Health Service Asbestos Bpidemiologlcal Study been completed as continually requested by the Asbestos Textile Institute, we might now be in a positi n f having factual information as to what the safe threshold limit for asbestos dust really should b . 4304 One factor is pertinent to this point. The asbestos related Mr. Arthur M. Goldberg Asbestos Hearing March 13# 1972 Page 5 ITS f"ie*Sstis5*: K' disease involvement in the asbestos textile industry is being related to asbestos dust exposure levels as they presently exist rather than at the time the disease was incurred 25-30 years ago. Such a comparison is invalid. All of the past monitoring for asbestos dust in American textile plants has been done using the impinger method for sampling. Today's propos d standards are based on a fibre level using the Milapore filter method for sampling. There is no accurate correlation of impinger counts versus Milapore filter counts established to date. There has been some work done by the United States Public Health Service# but the results are incomplete. This is but one area that dem onstrates the need for further health research studies and eval uations before unnecessarily creating an unrealistic standard that can be the demise of this industry and its related job opportunities. 7~Bb"qq230iT~T We respectfully urge the Secretary of Labor tot (1) Reconsider the establishment of.asbestos standards; (2) reinstate the thres hold limit value for asbestos dust at 12 fibres per milliliter# 5 microns or greater in length for an interim period pending a comprehensive epidemiological study of the entire asbestos in dustry in the United States. I would like to point out that many comparisons have been made between the British and United States asbestos textile industry concerning health problems. The vast differences in materials# equipment and processes make such ccmparis ns unrealistic. (3) Provide for repr sentation.. f the Asbest s Tfxtile Institute n-future advisory and study Mr. Arthur M. Goldberg Asbestos Bearing March 13, 1972 Page 6 committee*. i!nH;:S HIESJi'HC fauivi fV'k .- Z would also like to point out that while many detailed requir ments are included in the proposed standard, it is absolutely mute on the very important medically substantiated problem of cigarette smoking as associated with exposure to asbestos fibre. We. of the Asbestos Textile Industry, have the greatest desire to prevent injury to our employees. We believe this can be accomplished without destroying the asbestos textile industry. Thank you for the privilege of appearing at this hearing today. Very truly yours. .ex Xu Treasurtafand Member ox Board of Governors f r the Asbestos Textile institute akt jc 7*"bB 00 23012^2. document was^not^ M IU5 WO CANNbT BE AUTHENTICATED PG 1NDUSTR'ES> WC.