Document 91amXyo9Mo6On65M5ao7JeD7V

NATIONS INSULATION MANUFACTURERS ASSOCIATION 441 LEXINGTON AVENUE NEW YORK, N. Y. 10017 ASBESTOS CEMENT PRODUCTS ASSOCIATION 521 FIFTH AVENUE, 20YH FLOOR NEW YORK, N. Y. 10017 "vS PLAINTIFF'S EXHIBIT CAP-1545 March 5, 1971 PUBLiC STaT-.. CITY OF BOSTON AIR. rOsLUTiOl'. CO. :?.OL CCMKTSS ION PROPOSED REGULATIONS NO. 5 .ND NO. 6 Gentlemen, I a:.; Cl iffore L. Shcc'aler. I represent the National Insulation Kannf acturcrs Association cr.d the Ashes res Cement Products Association. I serve as Chairman of the National Insulation Manufacturers Association Health and Safety Committee. Also, Chairman of the Asbestos Cement Products .Association Health and Safety Council. Via respectfully call your attention to the City of Boston Air Pollution Control Commission P oposed Regulation No. 5 "Especially Hazardous Materials".. and Regulation No. 6 "Miscellaneous Dusts and Dust-Producing Activities". Both of the Associations that I represent, support the adoption of codes, rules and regulations designed to control exposures. it CAPCO KIN 0001179 It is essential to protect workers that spray, and ether construction employees, frotr. exposure to potentially hazardous amounts of Asbestos orany other dusts, during the course of their work. X\a also support efforts to reduce or control the emission of dust allowed to escape into the community atmosphere. k'e strongly oppose, however, the complete banning of any useful or essential inc..using asnetos- cci>aim oducts, cn the unproven allegation may constitute s health hazard to the general public. "..'a are compel 1 cd to voice misgivings cor.cer i tv t**1u111 ?a. 11 or the beginning of establishing an extremely dangerous precedent. This Regular would `car. a mo aerial primarily essential to men's safety and well-being. her. materials poss ess some of the properties of asbestos - none combine them all. It is this uni:;ue combination of properties OuiCCiJ 5003HOS i ""LC* 2. S O C`11*S 0 J. C to so many app locations. There is evidence that where adequate control measures were instituted the spraying of asbestos insulation could be controlled to the degree that only the normal, trivial amounts of asbestos were found in the ambient air, Radiation is a hazard but we do not ban x-rays - instead we control the hazard. Automobiles emit carbon monoxide but we do not ban automobiles - instead we attemot to control the emissions. .si :APCO KIN 0001180 -3- The opinion chat asbestos can and should be controlled instead of banned is. shared by '".any of our leading medical scientists. I respectfully call the Committee's attention to comments by Dr. Lewis Cralicy, U. S. Department of health. Education, and Welfare; Public Health Service, presented at the XVI International Congress on Occupational health, Tokyo, September 1969; "Asbestos can be used safely in tiodarr. technology if adequate precautions are taken to prevent excessive and unsuspected exposures". ic October, 1969, Volume 100,Humber 4, of the Official Journal of the cr.erican Thoracic Society, there is 2 paper entitled "Asbestos and in b?6?': bv Dr. Ceor.ue V'. V.'riuht. Dr. Wrix'nt said: "The- relationship between asbestos end health of humans, as reviewcble in 1969, indicates that serious exposures to asbestos fiber can occur in certain occupational and immediately adjacent environments. Fortunately, the con centration of asbestos fibers in these settings can be controlled. The environment of the insulation workers is more difficult to control than the more fixed and permanent environment of the factory and associated neighborhood. An approximation of the concentration of respirable-sized asbestos fiber that can be tolerated without the risk of pulmonary fibrosis has been achieved. There is reason to believe that this concentration will .... (Cont`ri. ; CAPCO KIN 0001181 -4- also minimize the risk of pulmonary malignancy including mesothelioma. Because of the long time lapse associated with the development of malignancy, longer periods of observation are desirable for a final decision on this point. There is reason to believe that the occupational use of asbestos fiber can achieve the sane degree of safety as the use of explosives, radiation, and beryllium, although extensive alterations may be required in the control of production and manufacturing, the containment of asbestos fiber so that none escapes to the outside, and the proper disposal of solid wastes containing the fiber. The rish to the general public posed by the mostly intermittent exposure to the low concentrations of asbestos likely to be present in the ambient air has been exaggerated beyond the limits imposed by known facts. Research to develop the necessary additional information upon which appropriate and realistic measures for safe use of asbestos fiber can be taken should be the goal in the next few years." On February 26, 1971, Dr. Irving Sclikoff appeared before the IIcw York City Council Committee on Environmental Protection. Dr. Selikoff told the Committee that he objects to the ban on asbestos sprayed insulation end voiced misgivings about the CAPCO KIN 0001182 t t f 4* -5- precedent such a ban might establish. He indicated this type of action could lead to the banning of other materials and I quote;"ona substance after .another could be banned". Dr. Selikoff was a shed the question by a member of the Committee, "Are adequate protective d evices for the safe use of sprayed asbestos available today'.'". Dr. Solihof f ans'.'cred flatly, "Yes tt Dr. irvmg Sclmozr again reiterated these opinions before the Chicago Cit Council Committee on Environmental Control on March 3, 1571. The Mationa] Insulation ers and the Asbestos Com aeration urge this uoi ittuu to revise Regulation 5 and G. Delete a efercnce to banning c asbestos or ar.y other material. Es Clifford L. Shachler, Chairman National Insulation Manufacturers Association Health and Safety Comm.ittee Asbestos Cement Products Association Health and Safety Council CAPCO KIN 0001183