Document 8BQzEvMGdgMpMgK27kXzL9yd

*L- ^t!jh^Ui^ui.ui*^-' ,,V|ti>'i`lf^?ff*^_;tij c- m nOhth amf n*ca U ' ,,. ~ ' f c>.0 e,vG. ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway. Crystal Square 4. Suite 509 Arlington. Virginia 22202 (703) 979-1150 06J55877 NEW$ NOTES NIOSH-OSHA Asbestos Work Group Submits Report - Adoption of New Standard Recommended By NIOSH 30 April 1980 * Q The report on workplace exposure to asbestos, prepared by a joint NIOSH-OSHA Work Group, was released on Apr. 17 at a news conference sponsored by National Institute for Occupational Safety and Health. Concurrently with release of report, remarks were made by Dr. Anthony Robbins, Director of NIOSH, and Dr. Eula Bingham, Assistant Secretary of Labor (OSHA). The Work Group commenced its work last fall with the charge to "review the scientific information concerning asbestos-related disease and assess the adequacy of the current OSHA occupational health standard of 2 f/cc." Members of Work Group included: Richard A. Lenten, NIOSH, Work Group Chairman; Dr. David H. Groth, Ninr.n. Julm Mr Dement, A* NIOSH; Dr. Joseph K. Wagoner, NIOSH^JDr. J. William LloyfL.$ ' OSHA; Dr. Han K. Kanq, OSHA; and Robert i.. Jenniflqs, JLsqjjr jA OSHA. A& Principal findings and recommendations of the Work Group included: . There is no safe exposure limit for asbestos. All commercial and several non-commercial forms ^ of asbestos cause disease. (Work Group found no basis for regulating one type of fiber and not another.) . Optical microscopy continues to be the most reliable and economically feasible method for determining airborne levels of asbestos. Its lowest reliable detection limit is 100,000 fibers per cubic meter (0.1 f/cc). . Substitutes for asbestos should be used whenever possible so that non-essestial uses of the carcin ogenic fiber are eliminated. wv.-w: Page 2 06155878 . The report contains recommendations for medical testing procedures including chest X-rays, pulmonary function tests, observation of respiratory and other clinical symptoms. The Group also recommends that sputum cytology be evaluated as a surveillance technique. . Results of medical examinations should be reported directly to the employee, and aggregate medical ' information--without individual identifiers--should be reported to an employer's entire workforce. . Asbestos workers showing respiratory problems should be afforded the opportunity to transfer to jobs where there is no asbestos exposure. They should suffer no cut in pay or benefits to do so. The Group suggests that this program should be similar to the one now enforced by OSHA for lead workers. . Asbestos product manufacturers should perform air sampling in all possible processes involving their -----------a^ products to determine probable airborne asbestos levels. This information should be passed on to the products' potential users. Dr. Robbins stated that NIOSH endorsed the findings and rec ommendations of Work Group, and was formally recommending that i OSHA issue "a safer standard for workers exposed to asbestos and that it eliminate from the workplace ali exposure from new non-essential uses of asbestos." In NIOSH's letter of Apr. 17 to OSHA, Dr. Robbins recommended that the permissible level for exposure__fcn asbestos ..dust .be. at lowest level "accurate!y measurable by optical microscopy" (0.1 f/cc). According to Dr. Robbins, NIOSH, in order "to further under stand the problem of removing all asbestos from the work en vironment," will undertake following additional studies: . Examine the life cycle of asbestos, from mining to fabrication, use, and disposal. This work - will identify all points where workers may be ex posed to asbestos and simplify enforcement of the new standard. (NIOSH will coordinate with EPA.) . Produce an inventory of all asbestos products likely to reach the work environment. This in ventory, along with the life cycle study, will help quantify the scope of efforts required to eliminate asbestos exposure. . Establish a continuing review of the development of asbestos substitutes. This should protect workers by encouraging rapid elimination of asbestos uses. n: (* *. . V . Vv . ..' Page 3 06155879 . Review laboratory facilities available for accurately analyzing asbestos since any new standard will require increased analytical capability. In her remarks. Dr. Bingham said "asbestos is now perhaps the foremost symbol of this country's concern about toxic substances in the environment and in the workplace." She added that a team has been designated within OSHA to begin working on a proposed revision to the present asbestos standard and that it would be developed pursuant to OSHA's cancer policy announced in Jan. In regard to the Work Group's and NIOSH's recommended 0.1 f/cc standard, Dr. Bingham said, "I can't tell you yet what permissible <<r level will be proposed or whether we will issue an emergency temporary standard or pursue the proposed permanent standard route." In response to a question about relationship between smoking and asbestos exposure. Dr. Bingham stated that this issue will be addressed in future hearings on a new standard. She added that it is likely that there will be an "enormous" public record developed during rulemaking process. On Apr. 25, AIA/NA President T. A. Dougherty issued an Association statement emphasizing that the NIOSH-OSHA Work Group report fails to justify the recommended twenty-fold reduction in the permissible exposure level, i.e. 2 f/cc to 0.1 f/cc. Attention was invited to report's extensive use of epidemiologic evidence from worker populations exposed to asbestos at levels many times greater than those experienced in industry today. Dougherty urged NIOSH and OSHA "to make responsible, scientific assessments of the health risks and health benefits to be gained before pursuing the type of drastic exposure reductions now being proposed." Dougherty stressed that NIOSH's proposal was not based on any scientific demonstration of the health-related value of such a reduction, but rather only on NIOSH's assertion that .1 f/cc represents the lowest level accurately measurable by optical microscopy. He stated, "Such assertions should not be substituted for sound scientific assessment in determining permissible ex posure levels." Dougherty noted further that the industry is aware of no widely applicable technology that would consistently provide accurate measurement of airborne asbestos in the workplace at such low exposure levels. Dougherty urged NIOSH and OSHA "to avoid resorting to extreme regulatory measures without first examining the consequences of their actions -- both for workers and society as a whole." He emphasized that "We support reasonable regulations which protect workers from significant risks without needlessly impairing society's ability to deal with other hazards," and added that AIA/NA stands ready to assist OSHA and NIOSH, as well as other government agencies, in achieving that goal." It is understood that the asbestos standards team within OSHA is workinq on a revision to the present asbestos standard. Several unanswered questions remain such as schedule for issuance of a proposal (possibly ANPRM which would be in consonance with generic cancer policy) as well as approach for addressing construction industry. Indications are that any proposal will likely not appear before July 1. 4 * x<* - Page 4 06*SSB8t CPSC Authorizes Development of Ban of Certain asbestos Paper Products Consumer Product Safety Commission voted 5-0 Apr. 9 to grant petition from private citizen, and to ban asbestos paoer pro ducts that are sold as final products to consumers for consumer application and to contractors for installation in homes. Staff, as a result, is now proceeding to develop a proposal and commence rulemaking under Section 8 of Consumer Product Safety Act. (N&N Mar.). Petition to CPSC was for a ban on two asbestos paper products found to be available to consumer: pregummed asbestos paper tape and a household role of asbestos paper. Commission action granting petition applies to consumer products similar to those named in petition. Neither the petition nor the Commission's action concern asbestos paper sold as components of another pro duct however. Representatives of Association met with Commission staff Apr. 9 to assist with their effort to arrive at useful, working definition for asbestos paper as well as for "commercial" asbestos paper pro ducts. AIA/NA also provided agency officials with historic profile of asbestos paper industry. CPSC will continue to look at a wider range of asbestos-containing consumer products as indicated by agency's ANPRM issued Oct. 17, 1979 (N&N Nov., Feb.). Commission inquiry will take the form of a general order to manufacturer's (including importers) to obtain information on the use of asbestos in various consumer products as well as marketing information and results of any fiber emission ` tests on such products. A draft general order which had been circulated for interagency review has been amended and is currently awaiting approval by the Commission and subsequent review by the General Accounting Office. Upcoming Association Meetings Regular second quarter meeting of AIA/NA Board of Directors is scheduled for June 11 at Ramada Inn, 901 N. Fairfax St., Alexandria, VA, commencing at 9:00 AM. Robert L. Jennings, Jr. 1 Esq., Special Assistant to Assistant Secretary of Labor (OSHA) will be luncheon speaker. Association Executive Committee will meet on May 13 in AIA/NA office and on June 10 at Ramada Inn, Alexandria, VA. Technical Committee next meets on June 12 at Holiday Inn H (Old Town), 480 King St., Alexandria, VA, commencing at 8:30 AM. - association Submits Response to Alberta Proposed Occupational Asbestos Regulation 06155881 Page 5 Comments on a second draft set of asbestos occupational health, regulations were submitted to the province of Alberta in Canada by the Association on Apr. 11. AIA/NA's response suagested that certain provisions of the draft were overbroad. Examples included oroposal's labelling requirement which would be applicable to containers of all asbestos products. As an alternative, Alberta was urged to adopt an exemption from labellinc similar to that of the U.S. OSHA asbestos standard for products in which asbestos fibers are modified such as with a binder type material so that no airborne concentrations above permissible limits will result. Association also commented that draft's requirements for protective clothing should apply only to workers exposed to concentrations above permissible limits in lieu of to any workers exposed to asbestos. In addition to commenting on various provisions of draft, AIA/NA called attention to its Recommended Standard for Occupational Asbestos Exposure in Construction and Other Non-fixed Work Operations. This position paper, representing continuing commitment of AIA/NA to develop a workable program for protecting health of workers in construction industry, was presented Feb. 7, 1980, together with Association of Asbestos Cement Pipe Producers, to OSHA Subgroup on Health Standards, Advisory Committee on Construction Safety and Health (N&N Feb.). Alberta draft does not recognize unique nature of construction industry in regard to occupational health regulation and inapolicability of traditional fixed-worksite regulatory requirements to such industry. Present Alberta draft includes exposure limit of 2 f/cc for asbestos fibers except crocidolite and amosite. The proposed limits for crocidolite and amosite are 0.2 and 0.5 f/cc respectively. Regulatory Agencies To Cooperate On Inspections The Interagency Regulatory Liaison Group (IRLG), by publication in Federal Register Mar. 28, announced inrolementation of an inspection referral program. IRLG's announcementwas on behalf- of four of its member agencies: Environmental Protection Agency, Consumer Product Safety Commission, Food and Drug Administration and Food Safety and Quality Service of Department of Agriculture. Program constitutes a formal, standardized procedure for reporting observations of suspected violations to agency which is responsible for enforcing standard. OSHA, although it is an IRLG member agency, has chosen not to participate in referral program at this stage pending clarification of various legal points. Overall goal of Referral Inspection Program is to achieve early identification and correction of serious problems. This will be facilitated by training of inspectors from each IRLG agency to recognize situations which indicate possible violations of other agencies' regulations. Observations will then be referred to appropriate agency. Determination that actual violations exist will be made only by agency having legal jurisdiction over the suspected violation and then only on basis of its.own follow-up inspection. Page 6 M5S882 CPSC-EPA National Workshop On Asbestos Scheduled For July Consumer Product Safety Commission and Environmental Pro tection Agency are planning three-day workshop to "gather technical data on substitutes for asbestos." Workshop will be held July 14, 15 & 16, 1980 at Sheraton National Hotel, 900 S. Orme St., Arlington, VA - about 10 minutes from Washington National Airport. Speakers are expected to be primarily from industry and academia. Chairmen of technical/ economic and health portions will be Richard Guimond and Dr. James Rowe respectively, both from EPA. Following is advance workshop announcement as provided by EPA. Please note specifics for pre-registration information. Hotel reservations may be arranged by contacting Sheraton National Hotel/(703) 521-1900 - refer to workshop when making reservations. Formal notification, of workshop will appear near future in Federal Register. NATIONAL WORKSHOP ON SUBSTITUTES FOR ASBESTOS July (4-15-16. I960 Sheraton National Hotel Arlington. Virginia The Environmental Protection Agency and the Consumer Product Safety Commission are gathering data on substitute* for asbestos. All those with an interest in substitutes for asbestos are invited to attend. Technical and Economic Sessions Overview talks . asbestos-cement sheet . sealants . Regulatory status . Effects on innovation . Market control incentives Technical Work Sessions on substitutes for r paper and textiles . flooring . friction products . gaskets and packings . asbestos-cement pipe Health Sessions scope of Health Workshop overview of routes of exposure synthetic fibrous substitutes natural fibrous substitutes natural non-fibroussubstitutes 0 synthetic non-fibrous substitutes open discussion of scientific criteria for evaluating sub stitutes Product Review Session In addition to formal discussions, information on specific materials or products which can substitute for asbestos or asbestos-containing articles will be presented during a product review session. FOR PRE-REGISTRATION INFORMATION CALL MO-424-MtS IN WASHINGTON. D.C. CALL 554-1404 A>r,r>,. M/\y 06 C.P0 ^ ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway. Crystal Square 4, Suite 509 Arlington. Virginia 22202 (703) 979-1150 NIOSH-OSHA Asbestos Work Group Submits Report - Adoption of New Standard Recommended By N10SH 061509ER .30 April 1980 The report on workplace exposure to asbestos, prepared by a joint NIOSH-OSHA Work Group, was released on Apr. 17 at a news conference sponsored by National Institute for Occupational Safety and Health. Concurrently with release of report, remarks were made by Dr. Anthony Robbins, Director of NIOSH, and Dr. Eula Bingham, Assistant Secretary of Labor (OSHA). The Work Group commenced its work last fall with the charge to "review the scientific information concerning asbestos-related disease and assess the adequacy of the current OSHA occupational health standard of 2 f/cc." Members of Work Group included: Richard A. Lemen, NIOSH, Work Group Chairman; Dr. David H.-Grolli, TTTOfiTT, Tulin M'. DeM*u.t, NIOSH; Dr-. Joseph K. Wagoner, NIOSH-<j)r. J. William Lloyd , ^ $ OSHA';' Dr. Han Kv Kanq~, OSHA; and Robert L. Jenniflqs, ~TsqT*r ~jS OSHA. A0 . Principal findings and recommendations of the Work Group included: . There is no safe exposure limit for asbestos. . All' commercial and several non-commercial forms of asbestos cause disease. (Work Group found no basis for regulating one type of fiber and not another.) . Optical microscopy continues to be the most reliable and economically feasible method for determining airborne levels of asbestos. Its lowest reliable detection limit is 100,000 fibers per cubic meter (0.1 f/cc). . Substitutes for asbestos should be used whenever possible so that non-essestial uses of the carcin ogenic fiber are eliminated. Page 2 061509F9 . The report contains recommendations for medical testing procedures including chest X-rays, pulmonary function tests, observation of respiratory and t other clinical symptoms. The Group also recommends that sputum cytology be evaluated as a surveillance technique. Results of medical examinations should be reported . directly to the employee, and aggregate medical ' ^ information--without individual identifiers--should be reported to an employer's entire workforce. . Asbestos workers showing respiratory problems should be afforded the opportunity to transfer to jobs where there is no asbestos exposure. They should suffer no cut in pay or benefits to do so. The Group suggests that this program should be similar to the one now enforced by OSHA for lead workers. . Asbestos product manufacturers should perform air sampling in all possible processes involving their ------------^ products to determine probable airborne asbestos. levels. This information should be passed on to the products' potential users. Dr.- Robbins stated that NIOSH endorsed the findings and rec ommendations of Work Group, and was formally recommending that OSHA issue "a safer standard for workers exposed to asbestos and that_t. eliminate from, the workplace all exposure from new-non-essential mses of asbestos..".- In NIOSH-'.s. letter of Apr. 17 to OSHA; Dr. Robbins recommended that the permissible~level for exposure to asbestos dust be at lowest level "accurately measurable by.optical microscopy" (0.1 f/cc). According to Dr. Robbins, NIOSH, in order "to further under stand the problem of removing all asbestos from the work en vironment," will undertake following additional studies: ------- -----. --Exam-ine-^the'-life cycle of asbestos, from mining to fabrication, use, and disposal. This work will identify all points where workers may be ex posed to asbestos and simplify enforcement of the new standard. (NIOSH will coordinate with EPA.) Produce an inventory of all asbestos products likely to reach the work environment. This in ventory, along with the life cycle study, will help quantify the scope of efforts required to eliminate asbestos exposure. . Establish a continuing review of the development of asbestos substitutes. This should protect workers by encouraging rapid elimination of asbestos uses. Page 3 0615C9SC Review laboratory facilities available for accurately analyzing asbestos since any new standard will require increased analytical capability. In her remarks. Dr. Bingham said "asbestos is now perhaps the foremost symbol of this country's concern about toxic substances in the environment and in the workplace." She added that a team has been designated within OSHA to begin working on a proposed revision to the present asbestos standard and that it would be developed pursuant to OSHA's cancer policy announced in Jan. In regard to the Work Group's and NIOSH's recommended 0.1 f/cc standard. Dr. Bingham said, "I can't tell you yet what permissible level will be proposed or whether we will issue an emergency temporary standard or pursue the proposed permanent standard route. ii In response to a question about relationship between smoking and asbestos exposure. Dr. Bingham stated that this issue will be addressed in future hearings on a hew standard. She added that it is likely that there will be an "enormous" public record developed during rulemaking process. On Apr. 25 , -AIA/NA President T. A. Dougherty issued an Association statement emphasizing that the NIOSH-OSHA Work Group report fails to justify the recommended twenty-fold reduction in the permissible exposure level, i.e. 2.f/cc to 0.1 f/cc. Attention was invited to report's extensive use of epidemiologic evidence from worker populations exposed to asbestos at levels many times greater than those experienced in industry today. Dougherty urged NIOSH and OSHA "to make responsible, scientific assessments of the health risks and health benefits to be gained before pursuing the type of drastic exposure reductions now being proposed." Dougherty-stressed that NIOSH's proposal was not based on any scientific demonstration of the health-related value of such a reduction, but rather only on NIOSH's assertion that .1 f/cc represents the lowest level accurately measurable by optical microscopy. He stated, "Such assertions should not be substituted for sound scientific assessment in determining permissible ex posure levels." Dougherty noted further that the industry is aware of no widely applicable technology that would consistently provide accurate measurement of airborge asbestos, in the workplace at such low exposure levels. Dougherty urged NIOSH and OSHA "to avoid resorting to extreme regulatory measures without first examining the consequences of their actions -- both for workers and society as a whole." He emphasized that "We support reasonable regulations which protect workers from significant risks without needlessly impairing society's ability to deal with other hazards," and added that AIA/NA stands ready to assist OSHA and NIOSH, as well as other government agencies, in achieving that goal." It is understood that the asbestos standards team within OSHA is working on a revision to the present asbestos standard. Several unanswered questions remain such as schedule for issuance of a proposal (possibly ANPRM which would be in consonance with generic cancer policy) as well as approach for addressing construction industry. Indications are that any proposal will likely not appear before July 1. Page 4 CPSC Authorizes Development of Ban of Certain Asbestos Paper Products 06150951 Consumer Producz Safety Commission voted 5-0 Apr. 9 to grant petition from private citizen, and to ban asbestos paper pro ducts that are sold as final products to consumers for consumer application and to contractors for installation in homes. Staff, as a result, is now proceeding to develop a proposal and commence rulemaking under Section 8 of Consumer Product Safety Act. (N&N Mar.). Petition to CPSC was for a ban on two asbestos paper products found to be available to consumer: pregummed asbestos paper tape and a household role of asbestos paper. Commission action granting petition applies to consumer products similar to those named in petition. Neither the petition nor the Commission's action concern asbestos paper sold as components of another pro duct however. Representatives of Association met with Commission staff Apr. 9 to assist with their effort to arrive at useful, working definition for asbestos paper as well as for "commercial" asbestos paper pro ducts., AIA/NA also provided agency officials with historic profile of asbestos paper industry. CPSC will continue to look at a wider range of asbestos-containing consumer products as indicated by agency's ANPRM issued Oct. 17, 1979 (N&N Nov., Feb.). Commission inquiry will take the form of a general order to manufacturer's (including importers) to obtain information on the use of asbestos in various consumer products as well as marketing information and results of any fiber emission tests on such products. A draft general order which had been circulated for interagency review has been amended and is currently awaiting approval by the Commission and subsequent review by the General Accounting Office. Upcoming-Association Meetings Regular second quarter meeting of AIA/NA Board of Directors is scheduled for June 11 at Ranada Inn, 901 N. Fairfax St., Alexandria, VA, commencing at 9:00 AM. Robert L. Jennings, Jr. Esq., Special Assistant to Assistant Secretary of Labor (OSHA) will be luncheon speaker. Association Executive Committee will meet on May 13 in AIA/NA office and on June 10 at Ramada Inn, Alexandria, VA. AIA/NA Technical Committee next meets on June 12 at Holiday Inn (Old Town), 480 King St., Alexandria, VA, commencing at 8:30 AM. Association Submits Response to Alberta Proposed Occupational Asbestos Regulation r Page 5 061 SC'JZZ Comments on a second draft set of asbestos occupational health. regulations were submitted to the province of Alberta in Canada by the Association on Apr. 11. AIA/NA's response suogested that certain provisions of the draft were overbroad. Examples included proposal's labelling requirement which would be applicable to containers of all asbestos products. As an alternative, Alberta was urged to adopt an exemption from labellincr similar to that of the U.S. OSHA asbestos standard for products in which asbestos fibers are modified such as with a binder type material so that no airborne concentrations above permissible limits will result. Association also commented that draft's requirements for protective clothing should apply only to workers exposed to concentrations above permissible limits in lieu of to any workers exposed to asbestos. In addition to commenting on various provisions of draft, AIA/NA called attention to its Recommended Standard for Occupational Asbestos Exposure in Construction and Other Non-fixed Work Operations. This position paper, representing continuing commitment of AIA/NA to develop.a workable program for protecting health of. workers in construction industry, was presented Feb. 7, 1980, tooether with Association of Asbestos Cement Pipe Producers, to OSHA Subgroup on Health Standards, Advisory Committee on Construction Safety and Health (N&N Feb.). Alberta draft does not recognize unique nature of construction industry in regard to occupational health regulation and inapolicability of traditional fixed-worksite regulatory requirements to such industry. Present Alberta draft includes exposure limit of 2 f/cc for asbestos fibers except crocidolite and amosite. The proposed limits for crocidolite and amosite are 0.2 and 0.5 f/cc respectively. Regulatory Agencies To Cooperate On Inspections The Interagency Regulatory Liaison Group (IRLG), by publication in Federal Register Mar. 28, announced irndementation of an in spection referral program. IRLG's announcement was on behalf-of-four of its member agencies: Environmental Protection Agency, Consumer Product Safety Commission, Food and Drug Administration and Food Safety and Quality Service of Department of Agriculture. Program constitutes a formal, standardized procedure for reporting observations of suspected violations to agency which is responsible for enforcing standard. OSHA, although it is an IRLG member agency, has chosen not to participate in referral program at this stage pending clarification of various legal points. Overall goal of Referral Inspection Program is to achieve early identification and correction of serious problems. This will be facilitated by training of inspectors from each IRLG agency to recognize situations which indicate possible violations of other agencies' regulations. Observations will then be referred to appropriate agency. Determination that actual violations exist will be made only by agency having legal jurisdiction over the suspected violation and then only on basis of its own follow-up inspection. Page 6 CPSC-EPA National Workshop On Asbestos Scheduled For July 06.150993 Consumer Product Safetv Commission and Environmental Pro tection Age-ncy are planning three-day workshop to "gather technical data on substitutes for asbestos." Workshop will be held July 14, 15 & 16, 1980 at Sheraton National Hotel, 900 S. Orme St., Arlington, VA - about 10 minutes from Washington National Airport. Speakers are expected to be primarily from industry and academia. Chairmen of technical/ economic and health portions will be Richard Guimond and Dr. James Rowe respectively, both from EPA. Following is advance workshop announcement as provided by EPA. Please note specifics for pre-registration information. Hotel reservations may be arranged by contacting Sheraton National Hotel/(703) 521-1900 - refer to workshop when making reservations. Formal notification of workshop will appear near future, in Federal Register. NATIONAL WORKSHOP ON SUBSTITUTES FOR ASBESTOS ' July 14-15-16. 1980 Sheraton National Hotel Arlington. Virginia ( The Environmental Protection Agency and the Consumer Product Safety Commission are gathering data on substitutes for asbestos. All those with an interest in substitutes for asbestos are invited to attend. Technical and Economic Sessions Overview talks . asbestos-cement sheet . sealants _ ... . Regulatory status . Effects on innovation . Market control incentives . Technical Work Sessions on . .. substitutes for . paper and textiles . flooring . friction products . gaskets and packings . asbestos-cement pipe Health Sessions scope of Health Workshop overview of routes of exposure a synthetic fibrous substitutes * natural fibrous substitutes natural non-fibroussubstitutes synthetic non-fibrous substitutes open discussion of scientific criteria for evaluating sub stitutes Product Review Session In addition to formal discussions, information on specific materials or products which can substitute for asbestos o asbestos-containing articles will be presented during a product review session. FOR PRE-REGISTRATION INFORMATION CALL 800-424-9065 IN WASHINGTON, O.C. CALL S54-1404 GRACE / J Construction Products Division 0(ci^ I 035- <x TO; M. B. Cohan H. C. Duecker D. M. Kirven W. S. Zorkers February 21, 1979 REF: E. S. Wood's Memo of 2/20/79 re "South African Claims of Asbestos-Free Vermiculite" cc: R. H. W. J. M. Vining A. Eschenbach R. Hanlon R. Becker B. A. Blessington B. R. Williams J. W. Wolter Please correct your records to show that the meeting to discuss above subject will be held on Monday, February 26th, at 8:30 AM, in the First Floor Conference Room (Financial) and not on the 27th as originally stated. Thank you. / cgr CONFIDENTIAL LEGAL MEMORANDUM (ATTORNEY'S WORK PRODUCT) TO: M. DiBenedictis H. C. Duecker 0. M. Favorito W. S. Zorkers FROM: M. B. Cohan Re: African Vermiculite February 20, 1979 After having spoken at length with Dr. Duecker and reviewed analyses of African vermiculite by Arthur D. Little and McCrone Associates, it appears that the claim that African vermiculite is "asbestos free" is untenable. While the level of asbestos fiber is low, there is no question that chrysotile or other asbestos fiber can be found in African vermiculite. The question now arises - should this infor mation be communicated outside the company and if so to whom and how. The delicacy of this matter and the danger of creating the appearance of impropriety is such that careful consideration must be given to any action plan. I would like to sit down with all of you and anyone else you think should be involved and discuss the impact of the "asbestos free" claim and whether the available cures might not be worse than the illness. MBC/al M. B. Cohan