Document 6w7JXVr1a6zbLzJxKv2Dn7eJ9

INTERNAL CORRESPONDENCE t.\ E T A L S DIVISION To (Name) Division Location Mr. E. A. Piersall UCC - Metals Grand Junction, CO Copy to Messrs. R. G. Beverly G. J. Hanks, Jr. E. W. Kantz J. L. Myers File (w/e) "* "* ll P. 0. BOX 579 *4C25 ROYAL AVE., NIAGARA FALLS. NEW YORK l30; D4,c originating Dept. October 31, 1978 "Calidria" Asbestos Answering letter date Su*uct Regulation of Taconite Tailings as Asbestos Attached, for your information, is more on the EPA actions to regulate all mineral fibers as though they were asbestos. So far we have been able to convince their RECRA people that asbestos is already heavily regulated under NESHAPS and should not be also placed under RECRA. There are problems, however, in that asbestos is on the "priority list" that came out of the EPF/EPA court settlement and it is conspicuous by its absence. Best regards, "7 Harrison B. Rhodes HBR/rmm Attachment *J/M letter 10/9/78 only Johns-Manville Sales Corporation Ken-CarjH Ranch Denver, Colorado 80217 (303)979-1000 October 9, 1978 1, p. > z. Mr. Joseph Padgett, Director Strategies and Air Standards Division U.S., Environmental Protection Agency Research Triangle Park, NC 27711 RE: Hoy^Aljert-V&vJuhe -28:,^197o.Recommendation^JegajdlagLftliftr-* * -Re gu latlpn_ of.. Tac,onite/'A s p An "A s~b e s t o s_. Can c e'rTHa z ard- Dear Mr. Padgett: EPA's Carcinogen Assessment Group recently sent us a copy of Philip Cook's June 1, 1978 "DRAFT REPORT - ASSESSMENT OF POTENTIAL ENVIRONMENTAL HEALTH HAZARD ASSOCIATED WITH AIR- BORNE MINERAL FIBERS EMITTED DURING TACONITE ORE PROCESSING." In addition, we received a copy of Roy Albert's June 28, 1378 memorandum to you, setting forth his recommendation that EPA should regulate taconite as an asbestos cancer hazard. A copy of. Johns-Manville's comments on Dr. Cook's draft report and Roy Albert's recommendation Is attached for your careful consideration. We are distressed that Roy Albert, as Chairman of EPA's Carcinogen Assessment Group, would use Dr. Cook's draft report as a basis for recommending that taconite be regulated as an asbestos-cancer hazard. Not only does Dr. Cook's report present a superficial and incomplete assessment of the present state of knowledge, the assessment also contains various inaccuracies which we have noted in our comments. In addition, we question the propriety of relying on any health hazard assessment prepared by one who is trained as a physical inorganic chemist, rather than by one with ap propriate scientific credentials. Furthermore, we disagree with Roy Albert's conclusions re garding the potential health effects of short fibers. There is both human and animal evidence to show that short fiber lengths of asbestos are not fi'orogenic or carcinogenic. This evidence is not "suggestive" or "indecisive" as characterized by Roy Albert. Our attached comments refer to the various animal studies which clearly demonstrate that these short fibers are biologically inactive. In addition, McDonald's study of the Homestake Mine found no excess of bronchogenic cancer, or any other tumor, in this population exposed to short fibers. As indicated in our comments, althoi^gi^ (E^e0 Mr. Joseph Padgett October 9, 1978 Page 2 NIOSH study did report an excess of bronchogenic cancer in a smaller cohort of this population, that study is so plagued with scientific inaccuracies that it is being repeated. It is our hope that EPA would undertake a more complete and objective assessment of the potential environmental health hazards associated with airborne mineral fibers emitted during taconite ore processing before making any decision with respect to the possibility of regulation. It is our understanding that short fibers of the cummingtonite-grunerite series of minerals are commonplace in the general mining industry. Their presence in taconite ore is not unique. Therefore, if EPA were to accept Roy Albert's recommendation on its face, much of the mining industry would needlessly be regulated as posing an asbestos-cancer hazard. We would be glad to discuss any questions which you may have regarding the enclosed comments. Very truly yours. Richard P. Carter, Manager Government Affairs Health, Safety & Environment Department Enc. RPC/lc cc: S. Gage S. Jellinek W. Barber M. James R. Carton R. Albert D. Goodwin bcc : P. Kotin, M.D. J. Autry J. P. Leineweber D. Poutiatine B. J. Pigg* SUBJECT: Asbestos Cancer Hazard FROM: Roy E.` 'Albert, `Oiairnan Carcinogen Assessaent Group . .= TO: Joseph Padgett, Director ' Strategies and. Air Standards Division ` This is in response'to your eercorandun of May 3, 1978 ' requesting CAG assistance in deternining whether EPA should .... regulate taconito as an asbestos cancer hazard. ,In our opinion the answer should be in a, The attached, report by Dr. Cooic summarizes the present state of knowledge. In essence, there is suggestive evidence that :hnrf lengths~~oi asbestos may nutZ-bc librogcnic or carcinogenic ^o_` far as nesothclior-a is concerned but the evidenco is not decisive and there is no evidence one way or the other regarding the effect of fiber length on the induction of bronchogenic cancer which is the main health hazard. ... .Attachment Oi-`. .VJ1U "h cc: S. Gage S. Jellinek K. Barber M. Janes R. Carton E. Anderson CRU/2 copies CAG Pleading tv*; EAnderson/dj/6/27/78 libr;*::* Ji\ r.i\loi-tv.: t'.uul fn-rlxtA ftor. rlnlng, ntl.Hug, .in*\ u*:c of unbustuN nil- V.nt'Jii 11> c.ivn.t: .v.'-biJiLooi-'i, lung c.in.-cf, pJcinal pcriu>;io:-.l lecr-ot hulln::i:i, :>n.l j>v:troii.t i.r.tina) t roct c*ontc:i in tvm. Cliryn-.jt.ile and the crori.doliic ai*J r.auiiite- ; m nvscicliii (d vlch all these dis'.aoe:* ulillr. muhnpbyl lltc rained in 1`iulond is- avaicie.r* J .in excess lung cm/air risk and high incidence of pleur/A thickening an;'. elicitic.otion (1). lon-or.cup;;Lion A exposure: to usbeslo:. in the neiJiV.-?: bauds of industrial sources (2) or from- contact v-itli asbestos war hers (3) .leads to increased risk or lnusothelioaa. Fibrous ncphibale iniuernls released iron rock during 'non-asbestos rdn-ing operations pasc a less veil-defined risk of disease vhea ic.kn.lcd. Since., little, or no cpidetaiolcigical or unLu.A study date exists which can be applied specifically to each occurrence, risk cssessrznt often depends on cncjinrisou of physical and chemical properties tu asbestos and on ccrporisoa. of airborne fiber ccocentmtiona to coivtcutraticus associated with asbestos . disease. .V .- - -. .e, ,. uv* u Vi *r- Kl *r F. S; 4K Excess cancer and pneumoconiosis deaths have occurred for vorkcari exposed tc aerosols of talc contnuiuatcd with tre.molite, cLuthophyllite, erkt chrycotilc (4). A study of underground cioera in a gold cine with p.runtrite fibers has damans traced n. thice-fuid excess of respiratory* cancer \t%: mortality (5) hut a sub sequent study (6) of a larger cohort fro:: fee nets mine (not liicitud to underground workers) indicates do excess of respiratory cancer deaths. . - : - L- h'htt basis cueists for associating asbestos health lucrards with mineral fibers released by taconite mining avid benefication? E-ccausc of their * unique structure, chrysotile fibers are certain to be identical morphologically structurally, and chemically to various chrysccile flbsrc released by chrysotile asbestos miming end rcilllng. Comparison of sirpbibclc fibers to VnovD a-pb.iholc asbestos enter inis is core difricult because the various '. nmphibole minara-ls ore formed with both fibroin (osbastiforr.) and. non-fibrous *. habits. It is also probable that a gradation "exists between. extremely fibrous ana non-fibrous ccpbibole occurrences. , r^. tr-.-~yy> ^yt" A further complication is the propensity of nruhibalc minerals to cleave, or split along preferred crystal planes, vhen crushed and thus'produce particles with length to diameter ratios in excess of 3:1. Amphibnlc fibers produced from a--jhiloie asbestos such as rmsite cay also result fron cleavage, hnuaver. ho biological data exists to them different response to samples of ar.phibolo fibarc which differ only in subtle internal cosi-sl defect structure:; or in crystal face orientations although these properties may be related to tha asbcstiforc nature of the rJLnfcrnl scrple 'ine tern "fiber" in this discus:riou refers sicply to any free particle vlth a length to uidth ratio equal or greater than 3:1. a r. fy - 11 fs'.' ' .. ! '`Jk' * I .J ` i i 55* Mf t/- :.v:? I I(> A current popular theory boong .i,.;be*:( <>.'! health experts is tlut nay l.onj;* thin durable* fiber introduced .Into fclv.ne will induce mlSymnU. nonplnsns. i`Lant(*u (7) .tup) untied 17 fibrous; ;;Inn::!. of different dJ.r*.ciu;iorwil distributions into the pleurae of rat1* mid ubsiervef) rhat fibers less thau or e*vui:.l co 1.1; |ji: in dlaciitcT and greater then fi pit in length yielded the*, highest 'probability of pleural sarcoma. Extrapolation of Lhc.'.c vcsulLu to fiber carclivigeneuii; in nan is subject to consideration of the influence of tibc-L* dir.-enson on nerodynncic .beb/ivior,* ptnetrabiliLy, /aid clearance froas the lung; i.c., r.or.i of the potentially rare carcinogenic fiber sites nay have greatly diminished abilities to reach target tissue. The' genajraLly - ir! hI-* i:;- accepted greater cancer rich associated with crocidolile fiber inhalation nc compared to chryaotile fiber inhalation my result primarily from greater J4-- lung .retention of croeidolite fibers. ' `` . ... ' a- Asbeston aerosols invariably lave a vide ranee of fiber lengths and widths. F.vcn imirrJL cxpcriuxints can not provide absolute offect/fiber r.iae . .. .&-w * :)IVs- reiar.ioasbips cincc asbestos sarplto of uniform fiber size have not be^n \i prepared. Hats intrapericcmeslly injected with short ebrysotile fibers {i'li/. .less than 5 p= in erne test and 9S7. leas tl-.cn 3 pe in n aecond. test) incurred approxicutely a 4CX incidence in tunors, in a study' (S) vliich provides the closest association between short fibers and carcinogenesis.' rulcomry tissues of asbestos vorliers contain cany care sliort fibers tlion long vitli mi even shorter fiber Gize distribution in pleural tisGue (9). .. ... ...; ,j v., . i The Mnv.lrouc-eatal Protection Agency'G anir-jJ. teste of rucphibole fibers L* < obtained iron Reserve Mining Cor.p.noy (Pd;C) will not ha eotpleted until 19i>0. llliess tests involve intratracheal installation j intrapleural injection of 7>'.MC acphibolc fibers and aconite fibers in rats (10). The acpliibole fiber samples used arc representative of fibers found in air samples free Silver bay but not typical of aUL ar.p'nibole fibers present. r. fc- B In vitro tests of KKC arphibole, erosite, croeidolite, chrysotile^ anthcphyllite, crc-r.iolite, and a Don-fibrous gruaerite iudicate that the -' RKC nrphibole is lytic to sheep crytliroeytes and depresses rabbit alveolar mcrophoge celluJLar viability similarly to- the nnphibole asbestos samples whereas the non-fibrous grur.erite scale is not uctive. Cytotoxic effect in such in vitro tests has been linked to the ability to cause fibrosis but ic not necessarily associated vith carcinogenesis. Mineral fibers v.-ith structures and surface properties entirely different than the asbestos nine rail; can be carcinogenic. Palygorr.kitc, n fibrous clay ciueral, induced nr. many mesotheliomas, following intraperitonciil injection La rats, as chrysotile (11). The .extraordinary incidence of r.osorhel iona in n Turhir-h village (.12) is now thought to be n result of coolite fibers rclc-ared into the environment by erosion and use of volcanic tuff- (13). '< n1.1 Col "rf- CJvrn llit rli.-fieal', crrf!t.e))*p.rnjihic, ovl tvirpl.'ilop.Lcfll nlt:iluriry ot MIC /u">'*ibule i JlI"j to fibers, it i'* tost lil.c'.y tlm initiation r> /o:rc to It Irroce:ii rations of ihu'-'e fibers vajuIu produce nxhcstos disease. It Ji. inparf.-.itt to note that- at till:; tit-c no evidence of fibrosis in l:t 1" p|-.plciy.i*r- with V :u <' then I'D yc.ir:: iv^plojir./nr. li; foutiu by jiyl.i-untiry function studies and Ch-.xt radiographs (16), Hint Studies can not bo extended 'to-conclude rh.-ir. inure,aytd riel: oi' Ian;' cancer nod cx.'.nt.lioli'xaa lu ebi-ent. but Indicate t.li::t exposures to libera art considerably lower thuu tlor.e experienced by a s host, os workers in the past nnd `aneocinUcd vith ashontosis end cancer. lldSA'spot dust inspections for r.Jneral fibera indicate tier* weighted average. fiber concentrations in EllC vorkiug areas" are far brio;.* the occupational health r.taadardu for asbestos i:ca even further heLou the concentrations ushectos workers verc exposed to dccadta nj;p. . . .. _ l t ii ..'i Tlit cocrcunity air .n^hibole fiber roncentratiunu in Silver Bay, Jviiuic no to a. 1 have m>u been uel.l cluiracterir.od by transniusion electron rclcroscopa ar.alyGis of air sacoles collected on tcaabrane filtera. /ucphibole fiber ".. crmcciitratico.e at thros sites ,iv;' residential Silver Bay rare detenainad froa continuous air nonitorin,'* to average approximately 125,000 fibtsrn per cubic rater for the years 197''*, 1975, and 1976 (15). The electron niceoscope analysis vn'a pfirforeed vith c. technique essentially identical to the EPA provisional r-ethed published in August- 1377 (16) end vas iu excellent a gr errant with results reported independently for 12 air kor.plea by the r.inner.ora I)eparf.-ent of Health and lie. Sinai School of ldcdicine .. Hnvironrantcl Sciences laboratory. Three other laboratories participating I in the iacerliiboratory corpr.rison each used inferior analysis techr.1 quca I and produced data which failed to correlate with any other laboratories* * results (17). Air aacpIeG recently collected by Korina V during and after e prolonged chutdown of r.er.ervc JUni/ag Company are currently being analysed . I*:. '. ~r r . i: iLr>r:\ <' i ( i f ,: iI t Ud-l ' I cud appear to show very low nc-nhibole fiber concentrations in the Silver L- Hey air during t.be ohutdoun period. Although stack emission controls being t\ installed should greatly reduce fiber concentrations, fugitive dust fron the on-lcud tailings basin to begin operation In 19S2 pose an iraloa own l addition to scpliibolc fiber concentrations in the air of the Silver Bey urea i The dose response equation for bunen inhaled fiber erposure ia not weLl cstablLidiod and the ej-.istence of an erposure threshold, belou ubich incrcastd cancer rial: is zero, ic unknovn. /ecphibole fiber concentrations id tlie air near the taconir.c processing facility et Silver l'eyr llinnesota arc probably at least 1,053 tires lovor than past conccritr.ecions in the 1II , asbestos iudiustry which led to high incidence of asbestos disease. Evaluction of the- etiviroiu-ientnl liacard, houever, requires consideration of factors gucU as 2'i b-out per dny exposure, exposure initiation ut infancy, 1 potentially longer period of nccumdatud exposure, tuid ecceptahle i env; ror.r-ejital lieulth ri^k versus acceptable occupational health risk. ii i A cor.pounJing problec for assessing cancer rink at lower exposure levels in the increased lapse tire between initial, exposure and onset of disease (1C) i A\: 0 '6 C l' a V- Tlif nw vnlK:M<* r.v:illorJiig, health, n-J r.inevnlogicsl inf r..rc:atio: should not change tin1:: uri gl iviliv rtalud concern for the long-t.era hv:\lth of persona living *" tin: v icinity M loeunitc prucenr.ing incllicles which handle ure highly c<nit;u- r-U with ;;rpbU>nJ e or chrynor.'i lc fibers. Evil unions Co the ciivXro:i!.>anC of Mich fibers should ha c.outrollod with host available technology, Such controls ore' planned for installation. at Reserve lliuLuy, Coi-pany. It r.hou'ld be noted that, while the 8 th Circuit Court decision of K.nrch 14, 1979 staled: "The best that can he i:i:id is that the existence of thin asbestos centnwlnsnt in air and water gives rice to c ro&uonahlc radical . ccacftn fur the public health. The public*;> exposure to ns-beston fibers in water end sir creates none health risk. Such a coataniuaut niivuld be rtnovud," `: the fiiKiings of fact of the United States District. Court in the Reserve lllalng Trial ware not reversed -or nodificd by the 8th Circuit Courc. These findings of fact included: 1. ' ".'tiny of these fibers arc corphologically and chceiicnlly identical to ar:ssite asbestos and an even larger nunher are cjailer to euros ito asbestos." .' 2. "Exposure to these fibers can produce asbestosis, cesotheLio-ra, and cwicer of the lung, gastrointestinal tract, and larynx." 3. "Too discharge into the air substantially endangers the health of the people of Silver Ray and surrounding co:mnities as fax away as the eastern chore in Viscor.sin." - . . 4. "The present end future industrial standard for a cafe level of nebsstos fibers in the air in bared on the cerporience related to nsbostosis and not to cauc3r. In addition Its forr-ulatiori was influenced rrorc by teclins logical liiaitationa than health considerations." >I'yi i/ *w i.i n g; V*' * 4 Vi i*. VIX - $ t* Is ii ill '^ V|T- :' $ V>K?-* * Jssi. & p* 5.-. UYii fe> burfiel lii* 5. "The exposure of n non-worker populace cannot be equated with irdu.st-rir.l exposure if for no oilier reason, than the environmental exposure., as contrasted to a working exposure, is for every v hour of every day." I f" 6. "111110 there in a dose--response relationship associated with the adverse effects of asbestos exposure ai\d coy ha therefore a threshold exposure value below which no increase in cancer would he found, .tills exposure threshold ic not now known." I m h V. k^: . *. * * Cm .:i} K *% A C' 0-8 [l !i- r . Ci--c IEf ,1 Ki.-fercmn-i* 1. Ai-iiuy ot. Ket;c:n rh Against Ci.ncer (IAV.C), r.:nn>|-.r.-i).h-; on }v.. I i:: t -j on r> ( the Co vr innr.on > t: kink of Chrt.-.lr.nlr. to K-n, Au5.fM.nii. u'r'(i:'-V.V'(i'y'/7)7" .2 lU-Josir.o., li. I.. nn.l Thorpson, II. Ki.u;olhelior.a of pleura anil perii(oivuc foiluviiit; cvv-or.urf. to asbestos in the Loudon area. Hri i.. 7k Jkuhiiitt^ Hod., * 22.' 261-209 (1905). '! | * fIi' . X m. 3. Andersen, 11. A., Lilis, Ik, I>5U=, S. 15., Fj schbein,. A. S., and .. Sellkeff, I. J. TL-iiistiiolu-ccncacc asbestos neoplastic risk. . Ann. !k_Y.Acrd_. 8 = 1.. 271. 311-323 (1976). 4. lU.eInfold, H., Kessitc, .1., Kouyrmnr 0., and Zaki, 11. Mortality' taong. kale rein ere aud cillcrn iu K.Y. state. Arch. Environ. Health. 14, (.63-067 (1907). . '' .' 5. Cill.-.r;, J. D., Decent, .T. H., Lcrcn, F.. A., Wagoner, J. K. Archer, V. Z an.! Piiejer, H, ?. Unreality patterns acong hard rock gold rrintre c'xno.-u-J to no asbestiforc niueral. Ann. K.Y. Acad. Scl., 271, 336-344 (1976). 6.. McDonald, J. C. Presentation at the American Thoracic Society Annual Meeting of June 1977, Abstract iri American Kevin'..- of Kcspirnlory Dlnev-sc, 115(4), 230 (1577). ?>- te: I- m X 7. Stanton, li. F. , Lnyard, H.. Tegeris, A., Killer, E., Kay, M.. and Kent, E. Carcinogenicity of fibrous gloss: Pleural response iu the rat in rcOstiun to fiber dic'.snsion. J_. Uatl. C-inccr Inst., ! 58, 5S7-6Q3 (1977). " i 6. Pott, F., I!uth, F., and Friedrichs, K. Tisaoren der rette nach. i.p. iojckt'ion von pnaslileneu chryr.otil und benco(a)pyren, Zbl. Lake. , I_. Abt. Grig. Ik, 155, 463-469 (1972). !. i 9. Eignna, J., Sebastian, P. , Caudichet, A., ard Eomiaud, C. tleasur caent . f to- Irx* of asbestos retention in huor-ns related to health effects. U.S. i bureau of Standards Keating on Asbestos, Gaithersburg, Maryland (1977) . " 10. Coffin, D. L. and Paleknr, L. D. EPA study of biological effects of asbestos-like nincrnl fibers. U.S. bureau of Standards Keetir.n on t /vsbesLos, Caithi-rsl-urg, Maryland (1977). i' i i 11. Pott, F. , Uolgnar, 11., Friedrichs, K., and liuth, F. L'efiet oncongene ' dei; poussieres fib re us as: 1/ experiment ion anicale et ses tclntious aver la carcinop.'intse hucnir.e. Ann. Aunt. Fat hoi., 21, 237-246 (1976) U trC JcrU II ilV -illl.-tiS H . 12. Leris, I. Pleural tcesothelioTcns and asbestos pleurisies due to envivona?r.tal asbestos exposure in Turltcy: an analysis of 120 cases. li/icetfcpe bull, lied. Surg., _U, 165-185 (1975). Vi .w * t> r A fcii. ' *4 I II/.vv M COMMENTS BY JOHNS-HAKV.t LLL CORPORATION ON THE JUNE 1, 1978 "DRAFT REPORT - ASSESSMENT OF POTENTIAL ENVIRONMENTAL HEALTH HAZARD ASSOCIATED WITH AIRBORNE MINERAL FIBERS EMITTED DURING TACONITE ORE PROCESSING" BY PHILIP M. COOK, Ph.D. Initially, the title of the draft report leads the reader to believe that the report will provide an assessment of the potential environmental health hazards associated with airborne mineral fibers emitted during taconite ore processing. However, the report is no more than a collection of references from which the implication is made that there may be a health hazard as sociated with such emissions. In addition, it is incongruous why an individual with Dr. Cook's background was chosen to prepare a document of this nature. Dr. Cook's training as a physical in organic chemist in no way prepares or qualifies him to evaluate potential health hazards that might be present. Furthermore, it is likely that Dr. Cook is not without bias in his assessment of this situation, since he was the principal technical advisor to the federal government during portions of the Reserve Mining trial in 1973- This incidentally took place only one year after Dr. Cook received his doctorate from the University of Wisconsin. Set forth below are comments relating to specific paragraphs of Dr. Cook's draft report. ~ Page 1, paragraph 1. In essence, this paragraph is an allencompassing statement which implies that any type or level of exposure to asbestos fibers can lead to an increased risk of disease. Dr. Cook makes no attempt whatsoever to place the various types of exposure, i.e. occupational, para-occupational, and non-occupational in proper perspective as far as exposure levels and potential and actual risk of disease are concerned. Manifestations of asbestos-related diseases have not been associated with low level exposures to asbestos fibers, as is implied by Dr. Cook. The occurrence of asbestos-related diseases is dose related in terms of fiber levels and years of exposure. There is increasing evidence to indicate that even in para-occu pational situations, those who have developed asbestos diseases did receive high doses to fibers. The first paragraph erroneously implies that household exposures to asbestos have been minimal in the dose-relationship concept. It is likely that these exposures were substantial. As recognized by Selikoff and others, the impregnation of drapes, rugs, furniture, etc. with asbestos fibers and the constant resuspension of fibers in the respirable range creates an exaggerated hazard. These household exposures provide an opportunity for repetitively high, short peak exposures due to the shaking out of work clothes. Lacking specific dust counts A nU tuj rv.' over the appropriate time period, any conclusion that these exposures were minimal is totally unacceptable. Once asbestos is carried home by the workmen, it accumulates in the home; and its presence in the home is likely to become permanent. For example, it gets into the rugs, from which it becomes resuspended by movements such as brushing and walking. In consequence, family members are getting a 2^-hour a day, 7-day a week exposure, relatively speaking, rather than an interval exposure. Further more, in the home environment, an exaggerated opportunity is present for co-factors to be operating, such as smoking and other household pulmonary insults. At the New York Academy of Sciences June 1978 Science Week Con ference, E. Cuyler Hammond, reported on a study which he conducted with Dr. Selikoff and others which was aimed at finding out if exposure to small amounts of asbestos will lead to any long-term harmful effects. This study traced the fates of 5,550 men who lived in the community near an asbestos plant in Paterson, New Jersey between 19^2 and 195^. The researchers stated that it was safe to assume that people living in that community were exposed to asbestos. Samples of settled dust collected from the attics of houses near the factory still contained appreciable numbers of amosite asbestos fibers. However, the researchers failed to find any unusual incidence, of cancer among these asbestos-exposed people. This is evidence that a low-level exposure to asbestos has not led to any increased incidence of malignancies. Page 1, paragraph 2. The unqualified statements in paragraph 1 are followed in the second paragraph by a greatly over-simplified statement on risk assessment by Dr. Cook, which in contrast .in cludes a statement which implies that fiber concentrations are important in relationship to the risk of disease. As Dr. Cook has noted, the physical, chemical, and morphological properties of fibers are extremely important in comparing incidence of disease from one location to another. However, it is extremely important that other factors, which may have influenced the occurrence of disease, also be taken into account. An example of this is the relatively large difference in the incidence of disease which is found in miners and millers of asbestos fiber, as compared with insulation workers, which indicates that cofactors may play an important part. Page I, paragraph 3- We are at a loss to appreciate the relevance of the reference in the third paragraph to the study by Kleinfeld, et al, on exposures to asbestos in the talc mining and milling industry. These were not exposures to short "asbestos-like" fibers of the type encountered in taconite operations, but repre sented exposures to fibers of the type which have been shown in other situations to be capable of producing disease when present in high enough concentrations. While it is agreed that occu pational exposures to tremolite and anthophylite of sufficient dose and duration can produce asbestos disease, we do not see how this is relevant for inclusion in an assessment of the potential environmental health hazards associated with airborne mineral fibers emitted during taconite ore processing. hn ^ r, -3- Reference is then made to two studies of the Ilomestake miners who have been exposed to cummingtonite-grunerite fibers of relatively short dimensions. The first paper reports the research efforts of Drs. Gillam, Dement, Lemen, Wagoner, and their associates at NIOSH. The authors of this study reported an excess of both lung cancer and pneumo coniosis in this population. They attributed the excess to the presence of a form of asbestos in cummingtonite-grunerite ore. The NIOSH group totally dismissed the possibility that this excess was caused by other potential lung cancer hazards present in the mine, such as diesel exhaust, arsenic and radon daughters. Cigarette smoking habits were ignored. The increase in fibrosis was erroneously attributed to asbestos, rather than to free crystalline silica, known to be present in'the mine in substantial quantities. The Gillam, et al paper is fatally flawed due to its failure to understand the problems inherent in studying a small cohort. The authors' claim of excessive rates in the asbestos-related malignant and non-malignant disease categories is clearly based on poor and incomplete data analyses. Even if the claim were based on valid analyses, data to incriminate asbestos, rather than one or a com bination of other coexisting materials in the causation of cancer, are entirely lacking. To ascribe the excess of non-malignant respiratory disease to asbestos and ignore the known exposure to . high levels of free crystalline silica in the past, confirmed by the frequent diagnosis of silicosis on the death certificates, borders on irresponsibility. To ignor-e the potential for carcino genic and co-carcinogenic effects resulting from the mixed exposure to silica dust, arsenic fumes and particles, blasting powder fumes and radon daughters, and to arbitrarily ascribe all of their excess of cancer to asbestos particles is manifestly irresponsible and has no justification in the methodology of science. As a result of the serious concerns raised by Johns-Manville and others regarding the NIOSH methodology and conclusions, this study is currently being repeated by NIOSH. As Dr. Cook properly notes, a subsequent study by McDonald of a much larger cohort from the same mine indicates no excess of respiratory cancer deaths.. The McDonald study has greater scientific credibility due to its inclusion of a much larger population sample. Finally, it should be noted that neither NIOSH or the McDonald study found any excess of mesothelioma or gastrointestinal tumors. Since the McDonald study did not find any excess Incidence of bronchogenic cancer, mesothelioma, or gastrointestinal tumors, and since the Homestake Mine environment included fibers virtually all of which were less than 5 micrometers in length, one can con clude that long-term exposure to amphibole fibers with such physical dimensions, at least at the dose levels reported, does not induce the development of asbestos-related disease. a 2 08 G ? -I'ap;e 1, paragraphs *1 and 5. In these two paragraphs, Dr. Cook .Vnipllcs that it .is extremely difficult to extrapolate from the known biological activity of chryuoti le and various ainplilbole fibers to minerals which may be similar but not identical in crystalline form or chemical composition. While this may be true, based on the work of Dr. Stanton and others, it is the physical dimensions of the fiber, that is of primary importance, whereas subtle differences in chemistry and physics are of secondary importance. Page 2, paragraph 1. In the first paragraph of the second page. Dr. Cook refers to the work of Dr. Stanton and characterizes his findings by stating that "fibers less than or equal to 1.5 /< in diameter and greater than 8 in length yielded the highest probability of pleural sarcomas." Dr. Cook has characterized Dr. Stanton's findings in a rather incomplete manner, as Dr. Cook's characterization leaves one with-the impression that fibers less than 8 micrometers in length can yield tumors in these animal studies. However, such a characterization is not supported by the. findings of Dr. Stanton and others. For example, Stanton's fibrous glass studies show a high correla tion between the probability of tumor production and the size of fibers; the probability rising as the numbers of fibers thinner than 1.5 microns and longer than 8.0 microns is increased. Stanton's data show that the low tumor yield group and especially the zero yield group were treated with glass fibers that were either virtually 100? less than 8 microns in length or were thicker than 1.5 microns. In reporting the results of his studies, Stanton stated: "The results of these experiments raised at least two points that merit discussion, the relationship cf fiber dimension to mechanisms of carcinogenesis and the relevance of findings to human exposure. An earlier paper proposed that the fibers at the lower range of optical visibility (i.e. diameters < 1.5"/<<) that were exceptionally short (i.e. lengths <5/!() might account for the carcinogenicity of several types of glass and asbestos fibers (!_) This hypothesis was not supported by subsequent data (2), which along with that of the present report indicates that the fine diametered fibers that are very long, are carcinogenic and probably become more carcinogenic as their length increases. The negligible carcinogenicity of short fibers is perhaps related to the histological observation that virtually all coarse and fine diametered fibers with lengths of 8,/^or less are efficiently entrapped by phagocytes. Many of the smallest particles are transported to regional lymph nodes, but even those that are not seem completely sequestered within the cytoplasmic limits of macrophages and foreign-body giant cells at th- site of implantation. Similar observations have been made with chrysotile fibers in vitro (8). '____________ a20802 "'"Stanton, M. F. , Laynard, M. , Miller, M. , May, M. , West, E. : Carcino genicity of Fibrous Glass: Pleural Response in the Rat in Relation to Fiber Dimension. J_._Nat'l. Cancer Inst., 58:587-603 (1977). -J- Using fibrous glass samples of unusual specificity placed directly into the pleura of hamsters, Smith has obtained information quite similar to that reported by Stanton. Smith confirms Stanton's findings as to the strong relationship between length of the fibers and tumor development. However, Smith found no tumors with a sample in which 98of the fibers were 10 microns or less in . length. Animal studies by Pott, Wagner, Davis and others have also reported the induction of mesothelioma following the introduction of long, thin, durable fibers of various kinds into the pleura or peritoneal cavities. All of these researchers have induced tumors in animals by this method using a variety of durable fibers such as asbestos, fibrous glass, ceramic fibers, aluminum whiskers, and other materials, v/henever sufficient numbers of long, very thin fibers were intro duced. All of these researchers have been unable to induce tumors when only short and/or thick fibers are introduced. In the middle of the first paragraph. Dr. Cook implies that long fibers, which have carcinogenic potential, have greatly diminished abilities to reach target tissue. This inference by Dr. Cook is contrary to findings of long fibers in both animals and man in all areas of the lung following inhalation exposures to-long fibers. On the other hand, short fibers are quickly removed from the lung by the mucociliary and macrophage system. The only case where Dr. Cook's inference could be true is in the case of long chrysotile fibers which are curly and present a larger cross-section. This, larger cross-section causes the fibers to be trapped in the bronchial system, rather than permitting them to "penetrate to the distal portions of the lung. Page 2, paragraph 2. In this paragraph, Dr. Cook continues with his short fiber hypothesis. With regard to the study by Pott, Hugh and Friedrichs referred to by Dr. Cook, it has now been established that the sample used in that experiment contained a sufficient quantity of long fibers (greater than 10 micrometers in length) to induce mesothelioma. This, together with the massive doses of fibers which were used, can easily account for the tumors which were found in the animals. The reference to the work of Bignon, presented at the National Bureau of Standards in 1977, is another example of the presence of short fibers in the target tissue, with the unfounded presumption that they were responsible for the disease. This is extremely poor logic, in that the mere presence of an agent does not necessarily mean that it was responsible for biological changes. Again, the significance of the presence of long fiber in the pleural tissue of these workers is neglected by Dr. Cook. Page 2, paragraph 3- In the third paragraph. Dr. Cook refers to the work now being carried out by Dr. Pelekar using amphibole fibers obtained from the Reserve Mining Company. First of all, the fact that these fibers cause hemolosis of sheep erythrocytes A 2 0 8 C b) 0 and depress the activity of rabbit alveolar macrophages in no way can be related to their biological activity in the whole ' animal. There have been many attempts to make such blanket corre lations, but they have failed. Dr. Cook does correctly state that the cytotoxic effect in in vitro tests have not been associated with carcinogenesis. Unfortunately, Dr. Cook fails t'o note that the fiber samples being used in these tests are not at all representative of the fibers which are emitted from the Reserve Mining Company's taconite processing plant. These fibers were produced from a geological curiosity found' by IITRI personnel during a very thorough explora tion of the Reserve Mining pit. This sample represents an almost asbestiform occurrence of the mineral cummingtonite, which is normally carried through the processing system. It was ground to produce a sample which contained fibers, 85? of which were less than 5 micrometers in length. The remaining 15? contained fibers up to 100 micrometers in length. By comparison, the airborne fibers from Reserve's taconite processing plant contained probably less than 1? of fibers greater than 5 micrometers in length. To the best of our knowledge, there are no reports of fibers in excess of 10 micrometers in length. Therefore, the fibers being tested by EPA, as referred to by Dr. Cook, are not representative of actual human exposure to amphibole fibers emitted-from the Reserve Mining Company's taconite processing operations. Since these fibers are not representative of human exposures, the data which ultimately will be forthcoming from these tests will not be useful in assessing the potential environmental health hazard associated v;ith airborne mineral fibers-emitted during taconite ore processing at the Reserve Mining Company's operations or else where. It is interesting to note that Dr. Cnok only refers to Reserve Mining's taconite operations as if there were no other taconite processing operations in this country. Based on the title of his craft report, one assumes he would have examined emissions from other taconite operations. Page 2, paragraph In the final paragraph on page 2, Dr. Cook refers to two studies in which minerals other than asbestos have produced mesothelioma. However, neither of these studies are supportive of Dr. Cook's short fiber hypothesis, since in both studies sufficient concentrations of long, thin fibers were present to produce mesotheliomas. Page 3, paragraph 1. We are assuming that in the first sentence of this paragraph. Dr. Cook is referring to the amphibole fibers v/hich were specially obtained for EPA's studies. However, as pre viously indicated, these fibers are not representative of actual human exposure to taconite emissions. Dr. Cook is correct in noting that at this time there is no evidence of fibrosis in Reserve employees with more than 20 years' employ ment. Dr. Cook further notes that these studies cannot be extended to conclude that increased risk of lung cancer and mesothleioma is A008 0 -7- absent. While Ur. Cook'is correct In this regard, he attributes this solely to the low exposures to fibers. While Dr. Cook may be correct, he totally ignores the possibility that the fibers to which the Reserve employees were exposed are too short to induce fibrosis. Dr. Cook also fails to note that in other populations occupationally exposed to asbestos for periods of less than 20 years, an excess incidence of both lung cancer and mesothelioma have been reported. It is irresponsible for Dr. Cook to fail to even consider the possibility that the dimensions of the fibers to which the Reserve, employees are exposed are such as to render them biologically inactive, regardless of the level of exposure. Page 3, paragraph 2, In the second paragraph on page 3, Dr. Cook is guilty of not being objective about his work. In effect, he is saying that anyone who gets results which agree with him is doing good work, whereas- others are using ''inferior analytical techniques." There is considerable debate still going on regard ing the reproducability of analyses of environmental fiber concen trations. EPA is well aware of the problems in this area, and has reached the conclusion that it is impossible to regulate fiber emissions into the air without a reliable analytical method. Experts in this field generally agree that the Environmental Sciences Laboratory at Mt. Sinai in New York and Dr. Cook's labora tory in Duluth generally obtain higher fiber counts.-than other laboratories. Regardless of the accuracy of Dr. Cook's reported findings, we are unable to determine the relevance of the state-, ments he makes in this paragraph to an assessment of potential environmental health hazards associated with airborne mineral fibers emitted during taconite ore proizessing. Page 3, paragraph 3- In the last paragraph on page 3, Dr. Cook makes the statement that "the dose response equation for humaninhaled fiber exposure is not well established..." To the con trary, the data do show a dose-response relationship with regard to asbestos exposures, even though the precise level at which there will be no adverse impact on morbidity and mortality is not known. However, we believe that a critical review of the best available evidence indicates that a time-weighted average health standard of 2 F/cc will not have any adverse impact on the morbidity or mortality of individuals occupationally exposed to asbestos. As Dr. Cook recognizes, the amphibole fiber concentrations in the air near the taconite processing facility at Silver Bay, Minnesota are far less than the current OSHA permissible exposure level of 2 F/cc. Dr. Cook then goes on to imply that there may indeed be a health hazard due to the consideration of such factors as 2^-hour per day exposure, etc. However, there is no foundation upon which to even base an implication of a possible hazard. Two paragraphs earlier, Dr. Cook notes that there is no evidence of fibrosis in Reserve Mining Company employees with more than 20 years' employment Yet, most of these individuals received a 2^-hour per day exposure, if one includes the time spent at home and otherwise in the a i'06:1 -a- neighborhood of the facility. The literature, if showing nothing else, shows that background concentrations of asbestos are un related to any increase of disease. In addition, there is no evidence of any excess disease from non-occupational and non-para-- occupational exposures to asbestos. As we previously indicated, Cuyler Hammond's recently delivered paper at the New York Academy of Sciences meeting reported no. unusual incidence of cancer among people who lived in neighborhoods near an asbestos plant in Paterson, New Jersey, while at the same time the employee popu lation at that plant have exhibited a high incidence of asbestosrelated disease. Page The last page contains many citations from the original Reserve Mining trial and the decision from the U.S. Circuit Court - of Appeals. While these may represent findings by the District Court and Appeals Court, they cannot be taken as scientifically factual. It is disturbing to think that EPA, or any other govern ment agency, would even consider making health hazard assessments based on court decisions, rather than scientifica data. Since when has our judicial system become the source of complex scientific determinations? In summary, we have read with interest this as well as previous publications of Dr. Cook. In manuscripts that describe his analytical studies and other research, we respect his qualifi cations. We are at a loss, however, to understand or appreciate his qualification to prepare a critical review or assessment of a situation in which "Environmental Health Hazard" is the shibboleth by which regulatory action is proposed-?. Equally astounding is our information that Roy Albert has used this Draft Report as the basis for the conclusion that a health hazard has been demonstrated incidental to taconite ore processing. ajOS 1 2