Document 7MGbEepQMLdKaX5kk6Dqkd4kE

DIVISION and LOCATION TO: M?. John H. Ikrsh August 22, 1978 SUBJECT: Asbestos International Association The Most Import Points to be Included in an Industry Statement on Asbestos and Health Problems I have read Harry Rhodes' letter to you dated August 15, 1978 and note his concern about my attitude toward what triggers the medical surveillance of asbestos workers. I have also re-read the sections in the Excerpts from the Asbestos Industry Response to OSHA dated April 9, 1976. It is not my intention to insist upon unnecessary medical examinations, and I think that the'insertion of the word "occupationally" in the 3rd line of item 6.3 on page 2 between "employees" and "exposed", will considerably narrow the field. I am certain that the trigger for medical examinations should be "occupational exposure" and not over-exposure implied by limiting the surveillance to those "persons regularly exposed to airborne asbestos fibers in excess of the prescribed standards." The viewpoint expressed in the AIA document that it is unnecessary to keep under surveillance persons exposed to asbestos below the prescribed standard is not a valid one in the light of the acceptance by the industry that the exact level for the prevention of cancer has not been demonstrated. It is essential to build up data on low levels of exposure and, therefore, all "occupationally exposed" workers should be examined, regardless of fiber count. At the same time every effort should be made to insure that adequate records are made and kept, showing the type of exposure, duration of exposure and intensity of exposure for each individual to correlate, with subsequent medical parameters analyzed. If the asbestos industry wanted to make a positive contribution, the development of a viable technique for auditing the applicability of the provisions of the standard to various jobs and operations would be of immense value to workers, industry and regulatory agencies alike. Hilton C. Lewinsohn /as JH^O 7704 MEMO from the desk of DR. HILTON C. LEWINSOHN IuJq/ {p . Z i)U &J (ta? Uf&r^. Tujui $'UjlJ--7 CAAixaJ? aU4P Sb^m tfcie wWkw u>4o jiuu&iP W g^attuoxu^ -___ I'.f wiu ViTvi uaJ&: "ai^) o> &j ^a^&u-u-P . '\3tuo b ft*? b-e^QsiO t" &Up 4Mefy! w\ GtyxicA ttfeu4> V) (LU) OUXtefo te^e*p s/mJLuuJ) -eLu^S^i' JHM 07705 UNION CARBIDE CORPORATION METALS DIVISION P.O.BOX 579 NIAGARA FALLS, N.V. 14302 TEL: August 15, 1978 Mr. John Marsh Raybestos-Manhattan Corporate Headquarters 100 Oakview Drive Trumball, CT 06611 Dear John: I see only one serious difficulty with Hilton's comments on my 7/31/78 Draft (attached), i.e., with Item 6.3. In their response to the October 9, 1975 OSHA Proposal, the AIA/NA took a strong position that there was a minimum exposure level below which medical examinations should not be required. This position was based on the lack of medical usefulness of such examinations, the inefficient use of limited medical resources that would be spent giving such examinations, and the practical infeasibility of actually providing the number of examinations annually which would be required. It is my understanding that this is also to be our position in the forth coming OSHA asbestos rulemaking. An industry position that all employees "exposed to asbestos" should be subject to routine periodic medical surveillance would seriously undercut this approach. If we have a problem here let's discuss it as soon as possible. Regards, HBR/rmm Attachment Harrison B. Rhodes Technology Manager JHM 07706 DRAFT H B R-7/31/78 ASBESTOS INTERNATIONAL ASSOCIATION THE MOST IMPORTANT POINTS TO BE INCLUDED IN AN INDUSTRY STATEMENT ON ASBESTOS AND HEALTH PROBLEMS flct~ 1. Asbestos, like many other essential raw materials, mey be a danger to health if it is ^correctly used. .2 Cigarette smoking has a strong synergistic effect in increasing the af~ IUfiij ('aMiei hea-Hh risk^from exposure to asbestos. 3. Industry believes that a time-weighted average exposure of 2 fibers/cc i'xJuifVtU hfflilene >5^<_is ywrfa ar^ appropriate^ standard but recognizes that there is "Jjs; biclo^t'cal effrchf no conclusive evidence to either prove or disprove U.u app^ispi'iaLeiiPiSS a/ ` 9* this level. As a consequence of this uncertainty, exposure should be controlled to the lowest practicable level. 4. There is a long time interval between exposure and appearance of disease and present cases are associated with levels of exposure in the past greatly in excess of those experienced in properly controlled A modern operations. 5. Industry recognizes the need to control worker exposure to asbestos and favors strict enforcement of realistic regulations in cooperation <5ovPfOnvT)^ J t*4u^(xui Wiffiluudi y OmJ, fa* tUc&UL*i with puWc-authoH'tetgs, and trade unions. is fu bx^ tutj 6. Industry will continue to take all necessary actions to ensure safe A and healthy working conditions, cuj! B\f aioutavioc' eiMM0At*ihJ 7. The user of asbestos-containing products is generally not at risk if there are no subsequent finishing operations which generate exposures above the limit noted In Item 2. If there are such finishing operations t>y irJujfy ,* tl-J ^U*u.lio*P^ the necessary precaution^ must be taken. ^ (i rt, euotauv we rtiaf' A 8. ^Asbestos in the ambient air does not involve any documented-he^Tth-- ^i's risk/ to the corununity at large. J f-f ^^707 HBR-7/31/78 ASBESTOS INTERNATIONAL ASSOCIATION DETAILED STATEMENT OF THE INDUSTRY'S POSITION IN RELATION TO ASBESTOS AND HEALTH PROBLEMS j '-j 1. THE RISK TO HEALTH 1.1 Asbestos dust may represent a danger to health if it is inhaled. 2. ASBESTOSIS 2.1 If sufficient concentrations of fibrous dust are inhaled prolonged periods, fibrosis of the lung (asbestosis) may result^ smokers who-are- exposed to asbestos are-moresusceptible--to this ri-s-k-than non-smokers-. 3. LUNG_ CANCER om q0 GU 3.1 Asbestos workers de m>t seem to-be more susceptible to lung __ cancer than other people uf4ocs- they- smoke, nof wc** asbcjres. N i<IxJvitM, Cbai^ &k*dJ 3.2 Asbestos workers awPwnJvLid not At*-smoke or fey reduce their /* smoking to a minimum because smoking (particularly heavy smoking) considerably increases the risk of developing lung cancer. 4. MESOTHELIOMA dose- rrjjcnSe 4.1 There appears to be a dawr^relationship between exposure to asbestos and the incidence of mesothelioma--bwt fcjot all cases of mesothelioma can be associated with exposure to asbestos. 4.2 While some medical authorities take a positive stand, there is by no means general agreement about the alleged^ spgytfrrc -*^8 of crocidolite and amosite in the causation of this disease. t <xcJb&\G> 4.3 " The majority of Association members who currently use 1, take the view that -erocidolite can juiiXuul tu Le used provided that the precautions set out in the Associations publications are strictly A ' JHM 07708 s ' 2- - REGULATIONS AND THRESHOLD VALUES 5.1 The industry accepts the need for statutory regulations designed to ensure that asbestos is used safely^.--------- - 5.2 It is the industry's policy to .... . A m hr exposure to airborne asbestos fiber during manufacture to the lowest practicable level but in any case not to exceed the 2 fibers/cc limit. 5.3 In the absence of regulations in any country, the Association recommends that the precautions set. out In its publication "The Control of Asbestos Dust" should be observed. 6. MANUFACTURE 6.1 Asbestos may be used in industry provided that the dust control measures recommended by the International Association are observed. 6.2 It is the industry's policy that all of its employees should be fully informed of the level of risk to which they may be exposed. 6.3 It is the industry's policy to ensure that areas where asbestos is used are monitored in accordance with the regulatory requirements o cc of the country of use and that all employees^exposed to asbestos nhmrn thiBiiifiifcatiitr-rr ln-rl a*e subject to routine periodic medical surveillance. 7. USERS 7.1 If there are no subsequent finishing operations on products which release significant quantities of airborne fiber, it is generally acknowledged that there are no health risks to the users of the products. If finishing operations are undertaken, appropriate precautions wuuw h* b>_ke*Y for IwtU b WaO eonsrirs-tant with tha 1-eva 1 of fibor rolaaoed-, must hV'.abS'ewMcd. 7.2 Full information about possible hazards should be given to users of asbestos products. JHM 07709 -3- 7. USERS (Continued) 7.3 As yet there is no uniform policy concerning the use of warning labels on asbestos products but many members now believe that the industry should voluntarily label products where a possibility of significant user exposure exists. 8. MEASUREMENT OF AIRBORNE DUST 8.1 It is the industry's policy to take the lead in the development and standardization of reliable techniques for this purpose. T 8.2 The industry recommends that the membrane filter method be retained as the standard method of measurement of airborne asbestos concentrations until better alternatives have been tried, proven and correlated with it. Vif- jj/,n\ O^NERAL_ PUBLIC cfiWHcjb^) luj Tta udhjjAg fe ^ 9.1 The general public is not at risk from asbestos or asbestos A products. 9.2 Persons living near asbestos factories are not at risk provided the precautions issued by the International Association are r properly observed.^ file eiesl ^ gauW ^eoeJSet. 10. RESEARCH . 10.1 The industry supports research into medical and scientific questions associated with asbestos and asbestos-related disease. 10.2 The industry encourages publication of the results of this research irrespective of whether these results are favorable to the industry or not. JHM 07710