Document 82ZM0pMXygNN13JjmGB676M75

JC 1494 INTERNAL CORRESPONDENCE Vs-S- / r.L'TALS DIVISION To (Name) Division Location Hr. R. L. Folkman UCC Metals 38th Floor New York, NY 10017 Copy to Messrs. R. E. Byrne, Jr. J. L. Myers R. L. Schult W. C. Thurber File P.0. BOX 575-4625 ROYAL AVE., NIAGARA FAILS, NEW YORK H302 Date Originating Dept. January 4, 1977 "Calidria" Asbestos Answering letter data Subject Asbestos Exposure Dear Bob: This is in response to your letter of December 28, 1976 regarding the recent NIOSH statement on asbestos. It is a complex question to cover in brief and I leave it to your discretion as to whether you wish to transmit this entire letter or just the last two paragraphs to Mr. Kroft. On October 9, 1975 OSHA published a proposed rulemaking on asbestos which recommended allowable exposure limits of 0.5 fibers/cc average and 5 fibers/ cc ceiling. This recommendation was based on the hypothesis that asbestos is a carcinogen, that the only completely safe exposure to a carcinogen is no exposure at all, and that the 0.5 fiber level was the lowest level that was feasible to attain. (OSHA Is constrained by statute to consider the feasibility of any standards they propose but this is not an overriding consideration when worker health may be in jeopardy.) The NIOSH statement follows the same line of reasoning but goes even further in alleging that 0.1 fiber/cc is feasible and where it cannot be achieved asbestos should be phased out. It is important to realize that the NIOSH document is advisory and OSHA may accept or reject any part of it as they choose. The "one-hit" or "no safe level" theory of carcinogenisis that serves as the basis for these proposals is new and very controversial. The industry position, supported by their medical consultants, is that the current 2 fibers/cc is an appropriate exposure level with a reasonable margin of safety. It had been hoped that some compromise between 0.5 and 2 could be achieved. The NIOSH position makes this more difficult. The industry is making a well organized presentation of their view, but it is impossible to guess what the final standard will be. At the present time, our King City plant is generally meeting the 2 fiber level and,with particular attention to housekeeping,can probably achieve levels down to about 1 fiber/cc. For levels significantly below 1 fiber/cc, it would probably be necessary to move the ore pile, install additional vacuum equipment, and make wider use of respirators to achieve compliance. UCC 012951 A'WaOrOA ! n7 ji t Mr. R. L. Folkman 2- - January 4, 1977 The most critical impact of a very low standard would be on our customers who manufacture asbestos-containing products and most particularly on the great diversity of ultimate users of these products. A standard 0.1 fiber/cc could force many of them to turn to alternative products. Very truly yours, 7/ /$ H. B. Rhodes ^ HBR:cjb UCC 012952 A250 18 INTERNAL CORRESPONDENCE METALS DIVISION To (Name) Division Location Floor Number Dr. H. B. Rhodes Metals Division Niagara Falls, N. Y. Copy to 270 PARK AVENUE, NEW YORK, NEW YORK 10017 Dafe Or/gr'nofrng Dept. December 28, 1976 Floor Number Answering /fitter date Subject Asbestos Exposure Dear Harry: Would you please write me a couple of paragraphs which I can transmit to Mr. Kroft regarding the attached. Something on both our market place and our operations would be appreciated. Thanks. Very truly yours, RLF:hk Att. C:C. 1L M ft L S In R. L. Folkman 'A/7< \250 1 9 UCC 012953 ft A25Q2C ^ /rJ: ^ ^*KM* Drastic Cut in Asbestos Exposure Urged By Federal Agency for 250,000 Workers &-- By Gar. Bronson However, when the British plant was re Staff tti`iinrtrr'iif Tun Wali. Street Jocfnai. studied in 1972. it was found that there was a Federal researchers arc urging a drastic greater incidence of asbestosis than the reduction in the occupational exposure of British standard warranted. In fact. 36% of more than 150,000 workers to asbestos, a the workers exposed for 10 years to 19 years known carcinogen, to one-tenth ot the cur had some kind of chest abnormality, and the rent federal standard. Carcinogens are can rate of abnormalities increased with the cer producing or inciting agents. rate of asbestos exposure. fn an unpublished report, the National In Other studies show an increased mortal stitute for Occupational Safety and Health ity rate from cancer among workers ex recommends that worker exposure to air posed to asbestos, says John Dement, an in borne asbestos be limited to 100,000 fibers stitute Industrial hygienist. A British study per cubic meter of air in eight hours. In ad published this year showed that workers ex dition, the researchers want peak concentra posed to asbestos from 1933 to 1950 had 1.8 tions of exposure limited to 500,000 fibers times as much chance of contracting lung per cubic meter of gdr based on 15-minute cancer as the expected number of cancer sampling periods. cases in the general population. Mr. Dement Current federal standards limit asbestos adds that British scientists found that in to two million fibers per cubic meter of air. workers employed up to 15 years beyond This standard was promulgated by the Oc 1950, during a period when industry im cupational Safety and Health Administration proved its engineering controls and technol in 1972, at which time industry was given ogy tor plant environment, the excess can four years to comply Plants were required cer case statistics continued to show up. to set up improved ventilation systems. In "ExrcHk ot Cancer Risk" - the interim period, an "emergency" expo In a South Dakota gofd-mine study pub sure standard remained in force after it was lished this year, researchers found that the set by OSHA under pressure from the AFL- 440 workers had three times as many cases CIO. of respiratory disease as expected, based on The institute recommendations in 1972 to the state mortality rates. These workers OSHA were well below those actually car were exposed to less ths,n 25(1,000 fibers per ried out. "Our 1972 recommendations were cubic meter in eight hours. designed to protect workers from asbestosis. "We're saying reduce exposures (to as or chronic lung disease," says Verne Rose, bestos t to a bare minimum because we institute director for criteria documentation, can't tell you how low you have to go to 'but not necessarily from cancer. We are eliminate a cancer risk." says Mr. Dement. now suggesting the least' detectable expo All studies have shown an excess of cancer sure level in the workplace. The reason ts risk at all levels of exposure to asbestos." j that we don't know what could possibly be a The reason for OSHA reevaluating the as- j safe level of exposure over the working life be3tos standard stems from a 1974 suit by time without adverse health effects." the AFL-CIO's . industrial union department Lethal Quality documented against the Department of Labor complain The lethal quality of tiny asbestos fibers ing about several points in the 1972 exposure that lodge in the lungs is well documented. standard. The AFL-CIO petitioned for ! If the exposure to asbetos dust in the work changes to be made in the required medical place is slashed, industries that use the ma records that employers maintain on work terial such as construction and oil refining ers. and it requested that the timetable for may come under increased pressure to sub lowering asbestos exposure limits be stitute nontoxic materials. Asbestos is used stepped up., r in fireproof textiles, shingle insulation, and The federal court of appeals in Washing thermal piping, among other products. ton, D.C.. directed OSHA to reconsider those "It's not possible to establish a safe expo- two provisions of the standard. At that time, sure'level tor the carcinogenic activity of as the enforcement agency decided the stan bestos." says Dr. John F. Finklea, director dard possibly wasn't protective enough of of the Institute. "Therefore, emphasis should asbestos workers' health and it decided to be placed on' prohibiting the occupational repropose the entire standard, beyond the use of asbestos in other than completely 'court directive, says an OSHA spokesman. ctosed operations', and on substituting other OSHA enlisted the aid of the National In products whenever possible." stitute for Occupational Safely and Health in The 1972 institute recommendations on the re-evaluation to study new research de asbestor to OSHA were based in part on the velopments and explore advances in protec research of the British Occupational Hy tive technology as they related to asbestos giene Society, which evaluated 200 workers exposure. The OSHA spokesman said the in an asbestos factory Based on that work, agency will hold public hearings early next the institute concluded that a two-million-fi year on proposed revised standards before bers limit would prevent asbestosis. promulgating the final rule. UCC 012954 i.