Document 8Rw4nK04bJOoX2r9KkLXV0yYB

FILE NAME: Union Carbide (UC) DATE: 1978 Aug 15 DOC#: UC053 DOCUMENT DESCRIPTION: AIA Report - The Most Important Points to be Included in an Industry Statement on Asbestos and Health Problems with Cover Letter .J*l\ August 15, 1978 Mr. John Marsh Raybestos-Manhattan Corporate Headquarters 100 Oakview Drive Trumball, CT. 06511 Dear John: I see only one serious difficulty with Hilton's comments on my 7/31/78 Draft (attached), i . e . , with Item 5.3. In their response to the October 1Q75 OSHA Proposal, the AIA/NA took i strong position that there was a minimum exposure level below which medical examinations should not be required. This position was based cr. the lack of medical/usefulness of such examinations, the inefficient use of limited medical resources that would be spent giving such examinaticns, andthe practical of actually providing the number of examinations annually which would be required. It is my understanding that this is slso to be our position in the forth ccoommiinngg uOS, HhmA asbestos rulemaking. Ar."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 l e t ' s discuss i t as soon as possible. Regards, HBR/rmm Attachment ?<7Wwvp Harrison B. Rhodes Technology Manager 000046 JHM 07706 ! DHBRRA-7F/3T1./78 " a r r STOS INTERNATIONAL a s s o c i a t i o n IM O M net* ` Asbestos, m e .any other essentia! raw materials, ^ - * ^ n ger to health I f f t is ^ c o r r e c t ly used. 2. cigarette smoking has a strong synergistic e ffect in creasing e o r l u f ' j coMitA h h risk from exposure to asbestos. * fihor5/c, i th a t a time-weighted average exposure of 2 # J 3. Industry believes th a t a t i ^ 9 ^ . f c artsappropriate^standard but r e c o g n i z e ^ W h e r ^ ,,,, conclusive evidence to either prove or disprove i , this' lev el. As a consequence of th is 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 a s s o c i a t e d with levels of exposure in the p a s t g ^ in excess of those experienced in properly controlled modern operations. 5 . industry recognizes the need to control w ee ^ r exposure to asbes os and favors s t r i c t enforcement o ^ f i ^ i s ^ n e g ^ a t i o n ^ . is bikAqwJ , , ,i necessary actions to ensure safe 6. Industry will continue to take all necess y and healthy working conditions. - J * J`~ 1 ~ " ' J 7 ' The user of asbestos-containing products is generally not at there are no subsequent finishing operations which generate exposures . j < non, ? I f there are such finishing operations, above the lim it n o t e ^ n j t e m ^ . ^ the necessary precaution^ must be taken. -iivw ,S ,, V - w .1 taw A 8. ^ Asbestos in the ambient a ir Jocc not-. ^ ^ y ^ o c u m e n t e d - h e a l t h - frs qqqq^ . 07707 - 3- 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. MEASUREMENT OF AIRBORNE DUST 8.1 I t is the industry's policy to take the lead in the development and standardization of relia ble techniques for this purpose. 8.2 The industry recommends tha t the membrane f i l t e r method be i o_ c ' retained as the standard method of measurement of airborne asbestos F > ;> 1 concentrations until b e tte r alternatives have been tr ie d , proven and correlated with i t . ./A**1 GENER^L_ PUBL_IC. ^ ' 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, &e e u s j eunvov--^ ^ ^ e o e J S j , RESEARCH . ' '` . ... 10.1 The industry supports research into medical and s c ie n tific 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. 00005 JHM 07710 O'