Document 6w1n8GLngJ5M1NYmwNbO6yKLd

BC: J. L. Myers W. ,C. Thurber*'' File &SSZSTOS UNION'CARBIDE CORPORATION MINING & METALS DIVISION iO\( n? 1 s*1, :*:* > i) THE DISCOVERY COMPANY P.O. BOX 5/9 NIAGARA FALLS, N. Y. 14302 TEL: 716-278-3376 January 6 Mr. Robert H. Mereness Executive Director Asbestos Information Association/NA Suite 610 1660 L Street, NW Washington, D.C. 20036 RECE/ved JAN 8 1976 Dear Bob: This confirms our telephone conversation of December 29, 1975, and provides the information you requested. As we are all aware, both the present and proposed OSHA regulations call for annual medical examinations for employees exposed to "airborne concen tration of asbestos". This creates a tremendous compliance burden on manufac turers who use asbestos in only a part of their operations, processors who handle products containing bound asbestos, small intermittent users, and in fact on almost any operation where the airborne dust levels are consistently very low but still distinguishable from background. We will undoubtedly want to push in the industry position statement for a cut-off concentration level below which examinations are not required. In his recent talk at the AIA/NA Board of Director's meeting. Dr. Hans Wei 11-mentioned a new research study on the value of extensive medical survei11iance in reducing lung cancer. The survival rate for the subjects checked was found to be little different from those not checked. The fundamental rationale for the newly proposed regulations is the contention that asbestos is a carcinogen, particularly with regard to mesothe lioma. The study just noted suggests that annual medical examinations, regardless of their other attendant social benefits, have little or no value in protecting the asbestos worker from cancer. This would appear to be particularly true for a cancer such as mesothelioma. Since the key objective of OSHA is to protect the worker, it could be argued that medical surveillance is superfluous in this case. While it is doubtful that the industry would choose to adopt such an extreme position, it seems important that the question of the true value of medical examinations in protecting the worker from cancer be entered into the hearing record. It can at least serve as a basis to argue for some reduction in the present all-encompassing requirements. It was not clear from his talk whether Dr. Weill agrees with this interpretation or whether he plans to include a discussion of this research in his medical summary. In view of the time schedule we are all in, it seems to UCC 015327 Mr. Robert H. Mereness 2- - January 6, 1976 me that it would be very helpful to have an idea of his thoughts in this area to guide us as the overall industry summary is prepared. If Guy Gabrielson agrees, it is suggested that you or he discuss this with Dr. Weill. Best regards. Harrison B. Rhodes Technology Manager HBR:dal CC: Mr. Guy Gabrielson UCCO15328