Document 86GxY3VZKNwOo3d7em5YXdgm

- Jyp,, - 'nr T. p. Norris W. C. Thurber (Enc.) J. E. Walsh KC-File (Enc.) NF-File (Enc.) UNION CARBIDE CORPORATION P.O. Box 579 Niagara Fails, N.Y. 14502 By_ Mr. G. L. Dickson Date September 25, 1974 Ful1 Name Address Mfrs. of Allied Resin Corporation Weymouth Industrial Park East Weymouth, MA 02189 Distributor interviewed Mr. Charles Howland - President Mailgram & Telecon ii Informed by Charlie Howland to immediately stop production of Ml0605 "Calicria" Asbestos (RG-244 in plain brown unmarked bags) and to hold up shipment of additional material. Reason for this action is that the government contract with their customer has been terminated, apparently prematurely. Was assured by Charlie that it has absolutely no bearing on our product (toxicology, quality, service, etc.) but that the Navy has no need of the coating which was being supplied. At this time we have no "brown bag'1 RG-244 in King City except for a small amount of off-spec product which will probably be sold to ASTRO-STONE sometime in the future. However, the last carload on this order was shipped to their warehouse in Methuen, MA on September 5, 1974 and so at the time we were notified it probably was within a few days of its arrival. According to Charlie we are under no obligation to take it back and that the government will have to accept it. Discussed briefly the prospects of developing new applications with this customer but, as reported in ROC dated September 6, 1974, they do have two other projects in mind but both are a long way down the road. ACTION According to Charlie Howland there is nothing they or we can do about this loss of business. Their loss is considerably greater than ours, altncugh this is of little consolation at this time. Routine contacts will be maintained at Allied. typed 10/1./74 DOS MGK3UFA BUF 2-005898E268 09/25/74 waa aja ICS IPWMIZZ -6173376070 CSP M(H TDMT EAST WEYMoOT^m^ IP 14302 jjjcres W>st^.S gram i SCRVtCC UNION CARBIDE CORP ATTN GORDON DIXON, DUP PO BOX 5 79 NIAGARA FALLS NY 14302 STOP ALL PRODUCTION ON P51060S CALIDRIA ASBESTOS IMMEDIATELY HOLD BALANCE OF ORDER OPEN DETAILS TO FOLLOW ALLIED RESIGN CHARLES HOWLAND 0904 EDT MGMBUFA BUF Mr. Robert W. Flugge &C, Deputy Commissioner Department of Environmental Quality 95 Franklin Street Buffalo, NY 14202 Dear fir. Flugge: This letter and attachments provide the technical supporting information on the spraying of asbestos-containing materials which was mentioned in ny comments present ed on September 25, 1975, copy enclosed. These comments were directed to the pro posed Erie County Air Quality Code, Article 111, Title 9, Section B, on Asbestos. The spraying of asbestos has received substantial publicity as a health hazard, primarily as a result of the extensive use of sprayed-on asbestos as a fire proof ing and insulation material. Industry recognized that this practice, which involved materials containing 10 to 80% asbestos and little or no permanent binder, was hazardous; and, accordingly, it has been discontinued. However, it is our firm belief that various materials containing small quantities of asbestos can be applied safely by spraying with no significant hazard either to the worker or the general public, and further that such spraying can be done in total compliance with the Federal OSHA Health Standard dealing with asbestos and the EPA National Emission Standard for Hazardous Air Pollutants. The subject applications generally involve the spray ing of paints and coatings where asbestos is a minor but important constituent added to give critical properties to the material. These coatings are applied wet as a slurry or liquid thus precluding the generation of airborne asbestos dust in excess s of accepted Federal threshold limits. Our data were obtained at comnercial locations under routine operating conditions. Samples were collected in the breathing zone of the operator during active spraying procedures and do not include breaks, lunch, and similar non-working conditions. The results thus represent the highest exposure level for each particular operation and the time-weighted average (TWA) during an eight hour shift would be much lower. Environmental exposures outside the work area would be even lower than the TWA due to dilution by other air. All samples were collected on millipore filters and counted at 400x using phase contrast illumination in accordance with Federal OSHA regula tions. The data were obtained at 21 different industrial locations throughout the United States. These or very similar operations are probably practiced to some extent in Erie County. f For convenience, the data are divided into four catergories based on the char acteristics of the binder, and are presented in this manner in Tables 1 through IV . Details of the type and quantity of binder, the main uses, and the asbestos content are supplied with each category. An overall summary is shown below: A0878C SUfflART AIPBORHE ASBESTOS FIBER COiidEKTRATIOtlS VAPIOUS IfiOUSTHIAL SPRAYING OPERATIONS Application Util and Ceiling Interior Texture Spray* Exterior Will and Roof Sprays Resin.Baled Coating! (Boat nfg.. ship coating. Building maintenance coatings) Asphaltic Roof and Auto Undercoating Binder 1221 Starch, PVA. Casein ate. Vinyl 1 Acrylic latex Polyester A Epoxy Resins I as Sprayed 2-4 Asbestos S-as Sprayed 1-5 10-20 4 MX. 6-50 12 MX. Locations Stapled 7 2 9 Asphaltic 45 IS MX. 3 21 No. of Sancles 24 5 19 8 56-: Airborne Asbestos Fiber Concentration lhoers/ec>Sp Range Average 0.0-1.6 0.6 0.0-0.2 0.1 0.0-0.S 0.2 0.03-1.5 0 -l.i 0.3 0.4 It is noteworthy that the highest value found was 1.6 fibers/cc>5/t and only three out of the ,55 samples gave readings higher than 1 fiber/cc. In the three highest cases other values for the same operation were below 1 fiber/cc. The overall average was 0.4 fiber/cc in the breathing zone of the operator performing the spraying. On this basis we feel that the proposed Erie County ban on the spraying of asbestos or asbestos-containing materials is overly restrictive. In view of this the alternative wording in my presentation is proposed: "No person shall cause, suffer, permit, or allow visible emissions of asbestos dust from spraying of asbestos-containing materials used for fireproofing and insulation." Another alternative would be to modify your wording to exempt certain materials based .on our supporting data, as follows: "No person shall cause, suffer, permit, or allow surface coating by the spraying of asbestos or asbestos-containing materials, with the exception of water, resin, and asphaltic-based coating and laminating materials applied for decorative and/or maintenance purposes containing, as sprayed, an amount of binder not less than 501 of the weight of the asbestos present and a maximum of 15X by weight of asbestos." We appreciate the opportunity to comment on your proposed rule-making. Please contact Dr. Rhodes or me if we can be of any assistance in the final development of your standard, or if you require additional information. JLM/ejp cc: Dr. H-B. Rhodes bcc: R.E. Byrne, Jr. R.F.X. Fusaro J.V. Murray R-l. Schult W.C. Thurber- Ve^y truly yours, f.7yui &-C&S lofin L. Myers Q Marketing Manager i 40879! PRESENTATION TO ERIE COUNTY AIR POLLUTION CONTROL DIVISION September 25, 1975 My name is John L. Myers. I am Marketing Manager for Union Carbide's asbestos products with offices in Niagara Falls, N.Y. I have been involved with Union Carbide's asbestos business since 1956; and, since 1972 when the OSHA (Occupa tional Safety and Health Administration-Department of Labor) asbestos standards were published, I have also been heavily involved with federal, state, and local regulatory activities concerning asbestos. He presented testimony at the OSHA hearings on the asbestos standard in 1972; and I served as an industry representative on a committee to develop the federal EPA (Environmental Protection Agency) asbestos standards, which were promulgated in 1973. Asbestos standards are now being developed especially for the construction industry and I attended and presented testimony at a two-day hearing in Washington last week. With me tonight is Dr. H.B. Rhodes, my Technology Manager. One of his main responsibilities is to supervise the air monitoring service which we offer to our customers. Dr. Rhodes is chairman-elect of the technical sub-committee of the Asbestos Information Association and is also actively engaged in the asbestos/health question and regulatory activities. He attended a symposium in England last week on asbestos and health and is preparing an article for publica tion on the health hazards of asbestos in certain segments of the construction industry. His training in air sampling and analysis was obtained at special courses offered by NIOSH (National Institute for Occupational Safety and HealthDepartment of Health, Education and Welfare). Dr. Rhodes has also performed extensive air sampling in connection with the use of asbestos in various compounds A08792 which ere scrayed on surfaces. This was dona to substantiate our position that relatively low levels of asbestos can be used in many products which, upon stay ing, do not cause any significant amount of asbestos dust. At your discretion, we can send this supporting information to you in the next several days. Union Carbide is engaged in the mining and milling of asbestos fibers at its plant in California, and we market asbestos fibers throughout the world. Ue supply asbestos as a raw material to compounders or manufacturers of various products, some of which are sprayed. We do not supply asbestos for use in spray fireproofing or insulation materials; and, in fact, neither does anyone else. Asbestos has essentially been eliminated from such products because of the attendant potential hazard to workers and the general public. Our interest in regulatory actions is to prevent ambiguity and to avoid the promulgation of standards which are difficult or impossible to enforce because of their generality. We want to assist in the development of standards which eliminate or minimize asbestos exposure, but which do not effect an unnecessary prohibition against the general use of asbestos, especially in products which present no ultimate hazard to the general public. Following are some excerpted quotes from a 1971 report of the National Research Council: "At present, there is no evidence that the small numbers of fibers found in most members of the general population affect health or longevity-----Asbestos is too important in our technology and economy for its essential use to be stopped___ Continued use at minimal risk to the public requires that the major sources of man-made asbestos emission into the atmosphere be defined and controlled." I think you would agree that these comments are closely aligned with mine. It is my understanding that you are considering legislation with the following wording: "No person shall cause, suffer, permit, or allow surface coating by the spraying of asbestos or asbestos-containing materials." The spraying of asbestoscontaining materials has received substantial publicity as a health hazard. A08793 primarily as the result of the extensive use of sorayed orocucts for fireproofing and insulation. Industry, government, and health groups have recognized that this practice, which involved materials containing uo to 80% asbestos with little or no permanent binder, was hazardous; and it has been discontinued. However, it is our belief, supported by the data previously discussed, that materials contain ing relatively small quantities of asbestos and suitable binders can be sprayed safely and in compliance with existing federal standards. We are strongly in favor of legislation which would prohibit the spraying of asbestos-containing materials for fireproofing and insulation which generate visible dust emissions hazardous to the public environment. However, the wording which you have proposed would inadvertently, prohibit the spraying of asbestoscontaining materials even though they generate no asbestos dust. These applica tions would include automobile undercoating, roof coating, textured paints, airplane de-icing, and many others which would adversely affect activities involving thousands of Jobs in Erie County. We therefore propose the following revised wording for your legislation: "No person shall cause, suffer, permit, or allow visible emissions of asbestos dust from the spraying of asbestos-containing materials used for fireproofing and insulation." We are confident that the above warding will accomplish your purpose, and ours; and that the safety and health of the general public will not be compromised or impaired by this revision. Thank you for your time and attention. John L. Myers Union Carbide Corporation Metals Division A08794