Document 992OrE8gGLJZnXJJYYJ2Yvg85

ASBESTOS TOXICOLOGY STATUS SUMMARY October 1972 UCC 013086 ASBESTOS TOXICOLOGY October, 1972 Introducti on Many people have become justifiably uneasy about the toxicological aspects of asbestos and recent federal regulations regarding its use. Unfortu nately, the publicity given to this governmental activity has tended to be of a sensational nature and has done little to place the question of asbestos toxicology in logical perspective. We take this opportunity, therefore, to state our firm belief that Union Carbide Corporation can comply with the regulations. Installation of additional dust control equipment at our plant to achieve compliance is substantially complete. Moreover, we believe that our customers can, without undue burden, comply with these regulations as they apply to their operations. With regard to the toxicity of asbestos, it is important to note that asbestosis and statistical excess occurrences of bronchogenic carcinoma have occurred only in connection with massive long term exposures to asbestos dust. The risk of this type of exposure is usually'in asbestos mines and mills and in manufacturing operations such as floor tile plants where asbestos usage may vary from 15,000 to 30,000 tons per year. The risk of long term massive exposure is generally not typical of operations utilizing the specialty type "Calidria" Asbestos products. ' The purpose of this short report, therefore, is to provide the "Calidri Asbestos user and potential user with a reasonable picture of the toxicology situation and a copy of the final 0SHA regulations on asbestos usage. Some limited information on handling procedures and control of dust generated by cutting and grinding that may be of particular interest for the small user is also included. It would be impractical and redundant for us to attempt to interpret, in a short report, the great mass of published matter, scientific and otherwise, that has appeared on both sides of the asbestos question. Instead, a small number of relevant articles have been selected and arranged by subject. It includes: Toxicology Information 1. Asbestos and Your Health Some direct answers to toxicology questions. Published by the Quebec Asbestos Information Service. 2. Airborne Asbestos ' The Summary and Conclusions section of a comprehensive study on asbestos toxicology by the National Acadeny of Sciences. The key conclusion is that the general public is in no immediate, danger from asbestos which is in sharp contract with much of what appears in the popular press. The complete report is available on request. A /t 'v'ji SOC O^ UCC 013087 2- - 3. Response to Article in Wall Street Journal When the OSHA regulations were published, the Wall Street Journal chose to attack them in an article that presented a very distorted picture of the facts, typical of much of the newspaper coverage of the question. This is the response to the article. 4. Several reprints from recent newspaper articles. Coverage is more objective. 5. The testimony of Dr. Wright before OSHA at the hearings on the proposed regulations. This is included for those seriously interested in the background of the toxicology questions. OSHA Regulations 1. Report Series on OSHA - June 26, 1972 Industry comment on the regulations and a brief summary of the main features. 2. Safety and Health Reporter - July 17, 1972 Plans and progress on regulations similar to asbestos on other substances. 3. OSHA Regulations on Asbestos 4. "Calidria" Asbestos Material Safety Data Sheet Dust Control 1. Transfer Devices Two apparatus arrangements developed by Dow Chemical to transfer their light Saran Microballoons. Similar devices have been successful for several small "Calidria" Asbestos users. 2. Vacuum Grinding Equipment In some applications plastics containing asbestos are abraided. Small amounts of fiber may be released. Here is one convient way to control the dust. UCC 013088 A r UD T3 =--3 'u a < 22 ESHu. ~" =o.i-32"ua ' >5.So--c SZ3i.cS - O.grt ' flj <^y ' C "rW - - vr~ e--j ,, , gEi'S's?- - J -S g I.'r:- e 'C- g ' < 1 -2 .. ' j /('< i _ }- 0 S' u S e r--s -03 :cl-`; '. ;. 'i .',J'] 7I Zi < H 2t 2 ^ ; - jdc es t/> q ' *s3 --- * * ' ^ '`'V , * .i2 i so u 0 . . ytv.-:Jf9i.ri ^ . Qi*0 s'*. g .E = '.S.SO-S."l-<C5S - '..; . '= .S-s aSg1^ "!*ii:aSSg Z*-- a-S-Si RS >' -. >>*o 4/ e -C ^[ c _ , o d m , I 0C .f0y C #j. 1* ' ,.W CL C >'! O *>-- X C * ' = a >> 5i ^ 0;n2 .0 . ir:."t ; <.-? P -o -o c -- *r -- ,!1w..- bV*h" 3fC> oZ -uSa oa' --.3 -3=.*03j=~= : '!'. rs; . .' 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UCC 013091 ft; 40GC AIRBORNE ASBEST OS A Report Prepared by the Committee on Biologic Effects of Atmospheric Pollutants * of the Division of Medical Sciences, National Research Council National Academy of Sciences National Academy of Engineering Washington, D.C. 1971 UCC 013092 06 CHAPTER T CONCLUSIONS AND RECOMMENDATIONS PATHOGENICITY OF ASBESTOS MINERALS . * . . Any of the commercially used asbestos minerals, when inhaled in sufficient numbers,' as in uncontrolled occupational exposures, can cause disabling fibrosis of the lungs. An association between occupational exposures to asbestos and bronchogenic carcinoma has been established, but the dose relationship and the role of cofactors have not been defined. Evidence of a causal association between some but not all exposures to asbestos fibers and diffuse malignant mesotheliomas of the pleura and peritoneum is substantial, but evidence of such a relationship with other tumors is inconclusive. Although the different types of asbestos differ in some of their biologic effects, no type can be regarded as free of hazard. The hypothesis that asbestos- fibers act as cofactors or carriers of carcinogens is attractive, but as yet unproved. EVIDENCE OF HUMAN NKfOCCUPATIONAL EXPOSURES TO ASBESTOS . The demonstration of ferruginous bodies, similar to those found in asbestos workers, in a large proportion of randomly selected lung specimens in many parts of the world is presumptive evidence that a. * persons with no occupational contact may have inhaled and retained asbestos. Proof has come in some areas with positive identification of chrysotile asbestos fibers. Analyses of community air for asbestos have been too limited to define the sources, concentrations, and distribution of fibers in the environment. The fiber concentrations that have been demonstrated in ambient air are small, compared with those in industry, but data are inadequate for definitive comparisons. 32 . UCC 013093 . ' . `A HOG? ESTIMATION OF RISK IN HUMAN NONOCCUPATIONAL EXPOSURES TO ASBESTOS The most important question in the case of persons with nonoccupational exposures to asbestos is whether there is an increased risk of malignancies. Industrial experience indicates that there is no likelihood of significant asbestosis in nonoccupational exposures. The major potential for risk appears to lie in those with indirect occupational contacts, household contacts, or residence in the immediate neighborhood of asbestos sources; and even there, the actual risk is poorly.defined. But the fact that there appears to be a gradient of effect in such groups suggests that there are levels of inhaled asbestos without detectable risk. It is not known what range of respirable airborne asbestos fibers will ultimately be found to have no measurable effects on health. At present, there is no evidence that the small numbers of fibers found in most members of the general population affect health or longevity. - HEED FOR AND FEASIBILITY OF CONTROLS Asbestos is too important in our technology and economy for its essential use to be stopped. But, because of the known serious effects of uncon trolled inhalation of asbestos minerals in industry and uncertainty as to the shape and character of the dose-response curve in man, it would be highly imprudent to permit unrestricted additional contamination of the public environment with asbestos. 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. In the absence of such controls, local fiber concentrations might at times approach those in occupational slte3. Analytic methods and epidemiologic data are inadequate for the development of ambient air standards, but emission controls are needed and appear feasible. _. '33 UCC 013094 0G I 4 Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 (212).661-8203 June 15, 1972 The Editor THE WALL STREET JOURNAL 22 Cortlandt Street New York, New York 10007 Dear Sir: It is incumbent upon any nev/spaper in this countryr especially when reporting on an issue relating to occupational or environmental health, to present evidence that is factual, well-researched, and free from distortion, error and'any possible taint of sensationalism. This is especially true when the newspaper in question enjoys the high reputation for fairness and accuracy of THE WALL STREET JOURNAL. Unfortunately, these basic precepts of sound journalism were not followed in a recent story in the JOURNAL. By this we specifically refer to the article on asbestos by Barry Newman that appeared in your June 7 issue, beginning on the front page. The article contains many major errors of fact and interpretation, such that it presents a com pletely distorted and alarmist picture of the asbestoshealth problem in the United States. The simplest way to demonstrate the truth of this statement is to examine some of the major errors contained in the Newman article. Mr. Newman began the article with a description of the supposed hazards faced by mechanics who blow asbestoscontaining brake lining dust out of brake assemblies with an air hose before replacing the worn linings. Had your reporter investigated this matter with any degree of thoroughness, he would have discovered a number of well established facts, namely that (1) the U.S. Public Health Service conducted a study which showed that less than 1 per cent of the approximately 50 per cent of asbestos in brake linings remains as free fiber in the dust after wear, the rest being converted by the high heat of friction Sponsored by Alla* A^totslos Co . Cement ArujnMnj Products Co.. Cerfaln-teH Pr.fJ*irts Cnrn . Fllpt'o'e Co., C*AF Corp., John* Marwlil Corp., National Gypsurn Co., Pniiuron Corp. end ?<:,bostoa-Mj.'Satlan Inc. UCC 013095 ^ *. 4 0 G *+ The Editor WALL STREET JOURNAL June 15, 1972 Page Two to a non-fibrous non-toxic material called fosterite, and (2) a study by Hickish and Knight, published in the British "Annals of Occupational Hygiene" in January, 1970, established that men engaged in the blow-out procedure described by your reporter had a Time Weighted Average exposure of .68 asbestos fibers per cubic centimeter of air, a level far lower than either the current United States standard of . five fibers per cc or the two fiber standard scheduled to go into effect in 1976. While these studies in combination demonstrate quite conclusively the lack of a hazard for men employed in brake lining maintenance and replacement, of perhaps even more importance in evaluating your reporter's alarmist approach to the subject is the fact that to the best of my knowledge, there have been no published or unpublished studies indicating the existence or even the suspicion of a hazard for these men. The conclusion is inescapable that your reporter selected this example to lead off his story . because of its colorful and alarmist nature rather than because of any factual evidence that an actual hazard existed. In the fourth paragraph of the story. Dr. Irving Selikoff of Mount Sinai Hospital is quoted as predicting 95,000 deaths from asbestos related cancer among the approximately 250,000 men currently employed in the asbestos industry in this country. While Dr. Selikoff is obviously entitled to make whatever predictions he choses, it is only reasonable to expect that a reporter seeking to write a balanced story would submit such a terrifiving prediction to other experts in the field for their comment. Had he done so, your reporter would unquestionably have been told that Dr. Selikoffs prediction is quite exaggerated and without solid foundation. The reason why this is so is quite simple. The two studies upon which Dr. Selikoffs prediction is based were of men employed in the industry for a minimum of 20 years and at a time (the 1930s and 40s) when dust levels were many times higher than they are today. Thus to apply the death rates resulting from long term exposure to dust levels existing 25 and 30 years ago to today's working population is plainly illogical. Had your reporter sought additional comment on Dr. Selikoffs prediction, he would have discovered this fact. -More- , UCC 013096 j\4 0 G h The Editor WALL STREET JOURNAL June 15, 1972 Page Three In the next paragraph, it states that "ordinary people who have come into contact with asbestos in the atmosphere" could be subject to asbestos-related disease. This same idea of a general public hazard is contained in the headline of the story: "Tiny Asbestos Fibers Pose a Health Threat To Workers and Public." While there is some evidence that in years past there may have been some potential hazard to people living in close proximity to uncontrolled asbestos mines and mills, as technology was developed for the control of asbestos dusts in industry from escaping into the community air, these potential hazards have been eliminated. As far as the general public is concerned, there never has been nor is there today a public health hazard as a result of exposure to the very minute amounts of asbestos.that have been shown to exist in the ambient air. This was the basic conclusion reached by a panel of asbestoshealth experts convened by the National Academy of Sciences to draft a report to serve as the medical basis for the Federal Environmental Protection Agency national emission standards on asbestos. The report, entitled "Asbestos: The Need for and Feasibility of Air Pollution Controls," states on page 19 that "there are levels of asbestos exposure that will not be associated with any detectable risk. What those levels are is not known, but there is no evidence that persons in the general population -- without occupational, household, or neighborhood exposures -- have any increased risk of neoplasm, even though there may be ferruginous bodies or fibers in their lungs," and in the Conclusion section on page 31 it states: "There is no evidence that the small numbers of fibers found in most members of the general population affect health or longevity." This booklet has received wide distribution. Had your reporter researched his subject with any degree of- thorough ness, he would certainly have been given copies of the report. If he was given a copy, he obviously completely disregarded it. A little later on in the article your reporter states that "bits of asbestos used in filters for beverage making have been found in wine and beer, for instance, and could be dangerous if -swallowed." This same question was raised in Great Britain a few years ago by writers also seeking . the sensational rather than the scientific. The furor died i ' i -More- ,. UCC 013097 ' & 40G6 The Editor V7ALL STREET JOURNAL June 15, 1972 Page Four when it was shown that the total amount of asbestos fiber found in British beer added up to only two-one-thousandths of an ounce in the total United Kingdom beer production of over a thousand million gallons a year. This translates into about five parts per million-million by weight. The additional fact that there is not one shred of evidence that ingesting such infinitesimal amounts of asbestos is in any way hazardous helped allay the fears of the British beer drinking public. The comment attributed to VJilliam Nicholson of Mount Sinai that shaking an asbestos-containing coat could result in . "dust levels as high as in an asbestos factory" once again demonstrates your reporter's search for the sensational rather than the factual. Had he chosen to look into the matter of the 200,000 asbestos-containing coats more thoroughly, he would have discovered, that the committee appointed by the Food and Drug Administration to investigate the problem concluded in its report that "this single episode of manufacture and sale of asbestos-containing garments did not constitute an 'imminent hazard' as defined by the Food and Drug Administration, and that a recommendation to recover all the garments from the individual purchasers was not warranted." Tests run on the coats by the National Institute of Occupational Safety and Health for the FDA were "deliberately designed to be many orders of magnitude more ' severe in terms of applying energy to the garments than would be expected in ordinary use by the public." In addition, "a build up of air-borne fibers was encouraged." Despite these severe wear and brushing tests, the amount of free fiber that became air borne was considered by the committee to provide "a wide margin of safety" for the wearer. Thus, while Mr. Nicholson's colorful quote makes attractive copy, it is not supported by sober, scientific fact. One of the most serious breaches of journalistic ethics is to deliberately quote an individual out of context. This was done in the case of Mr. J. B. Jobe of Johns-Manville, who was quoted as stating at Occupational Safety and Health Administration hearings in VJashington in March that it would be "socially irresponsible" to adopt a two fiber occupational standard in the asbestos industry. Mr. Jobe's full statement, which can be found in the official record of the hearing, was as follows: "V7here there is no scientifically credible evidence -MoreUCC 013098 ' A'4067 The Editor WALL STREET JOURNAL June 15, 1972 Page Five demonstrating the necessity of such low standards, it would be socially irresponsible to adopt them." By omitting the first part of Mr. Jobe's comment, the impression is given in the article that Mr. Jobe would be opposed to the two fiber standard on economic grounds, even if it were necessary to adopt such a standard in order to protect the lives of industry workmen. I need not point out the serious harm that could be done to Mr. Jobe's reputation by this outof-context quote. Your reporter's next major error is a relatively simple one of misunderstanding, yet had he made any efforts to discuss the situation with industry officials or to visit -a manu facturing facility (both of which were offered to your reporter by Johns-Manville), the mistake would not have been made. By this, I refer to those paragraphs in the article in which your reporter states that "the curbing of asbestos contamination is more an exercise in good house keeping than capital expenditure," and he then goes on to list a half-dozen "staples of such an operation, already in use in many plants." The mistake made by your reporter is that the "staples" he refers to, such as closed plastic bags for mixing cement, vacuum attachments on power saws, etc., are not used in plants where asbestos-containing products are manufactured, but in the construction industry, especially in the application of asbestos-containing insulations in buildings, power plants, etc. Asbestos dusts in manufacturing are controlled not by such devices but by highly sophisticated and expensive bag-house - type dust collectors and other similarly costly equipment. One visit to an asbestos manufacturing plant would have clarified this point for Mr. Newman. A similar error is made by your reporter when he reports that a Mount Sinai survey of 9,400 asbestos workers showed that there was only one dust count taken "in asbestos plants for every 20,000 man-days worked." Dr. Selikoff has reported on similar dust count frequencies for years, but always in reference to the construction industry, never to manufacturing plants, where dust counts are taken on a regular basis in most operations. Perhaps Mr. Newman's confusion.arose out of the fact that the term "asbestos workers" when used by Dr. Selikoff refers not to men engaged in the asbestos manufacturing.industry, but to those in the insulation application trades, who belong to a union called -MoreUCC 013099 A ' 40G3 The Editor ViALL STREET JOURNAL June 15, 1972 Page Six the Heat, Frost, Insulation and Asbestos Workers (my underlinin which is commonly referred to as the Asbestos Workers Union. Once again, a more thorough research effort on your reporter's part would have provided him with this information. Finally, I would like to register a very serious objection to a major error of omission in fir. Newman's article, as contrasted to those of commission referred to thus far. In the entire article, your reporter makes only one or two passing references to industry efforts to solve its problems in this area, and leaves the distinct but erroneous impression that the industry is trying to get away with doing as little as possible and that it started its control efforts- only very recently. Nowhere in the article can be found mention of the vast amount of medical research sponsored, co-sponsored or cooperated in by the industry over the past three or four decades, nor ,of the vast improvements in dust conditions achieved in manufacturing operations from coast to coast over the years. While information of this nature does not make for alarming headlines, it is as important a part of the overall asbestos-health story as case histories of disease and dire predictions of occupational deaths in the thousands. In conclusion, I hope that this rather lengthly letter has demonstrated quite clearly to you the incomplete, erroneous, sensationalized and distorted manner in which your reporter presented the asbestos-health situation in his article. On behalf of the member companies of the Asbestos Information Association/North America, we request in the interests of fair and balanced journalism, that this letter be printed in its entirety in THE WALL STREET JOURNAL; that the WALL STREET JOURNAL print in its pages an apology for the incomplete and distorted nature of the article; and that you assign a competent writer untainted by the desire for sen sationalism to write a balanced article on industry efforts and accomplishments in reducing asbestos-health hazards for workmen throughout the nation. Very truly yours, Matthew M. Swetonic Executive 'Secretary : UCC 013100 ` ; A 14063 "/orh times 7127112 - ............................... * '-* ; Asbestos Exposure. Is Linked to Cancer In Cigarette Smoker Ey T>.* Two cancer researchers say they have confirmed through human lung cancer cases the theory that occupational expo sure to asbestos enhances the cancer-causing effects of ciga- ' reita smoke. . Asbestos cynosure bv itself. tliov ro,iv?T'*.r/.> \05r<?rG?.v. , 7 i.iot gppeai to inrrease i\r* in : cicience o: cancer among : asbestos workers who do not : smoke. : These findings, the research ' ers said, confirm studies based r on such approaches as review- 1 ing medical records but also ' come from what they describe l as the first _study ~thev are i aware of based on actual lung i cancer specimens. ; TiTe report' in the journal 1 Cancer, a publication of the American Cancer Society, was written by two pathologists, ' Dr. Milton Kanr.erstein of the Sarnert Memorial Hospital Cen- ter in Paterson, N. J., and Dr. ; Jacob Chtirg cf the Mount Sinai School of Medicine in New j York. ` The pathologists said they i had compared 30 lung cancer cases in patients occupationally, exposed to rsbestos with 59 matched control cases in per-; sons nut e;:pr,..ed to asbestos. The incidence of lung cancer; among ci.aaretrc-sn'.okirtg csbcs- , tos v.vrk-'rs was J>2 times as ! high as it is for nor:smokers not exposed to asbestos. I "ft won'"; appear then," Dr. ' ICannersteiii and Dr. Chnrg said, `that it is as a corarcino- gen, in combination with ciga- retie smoking, that asbestos " has art effect.'" A similar situation has been suggested for king cancer m.vj.tg uranium miners, they said. i OjRLU street ctourkm. 7/27/72 . ... TIip link of to w.rcfr p.t.-;var> to hinro on V.riiing ia the jour nal Citncer, two pathologists said a study of human lung cancer cases h:.d confirmed the theory thr.t occupational exposure tv asbestos enhances the cuirwer-c.tusing effects of cigaret. smoke. Asbestos exposure, the'-' said, doesn't appear to increase the inc'.d- pee of Inn; among those workers who csr.'t smoke. A&7%//</} i/^/z f Cancer researchers investigating the tie between lung cancer and as bestos repot ted that exposure to the material appeared to increase the .likelihood cf cancer only if the vic tims also smoke eiadTTTTf Tvro uuth*dTogisTs--v.-no examined ICO iunaca.neer specimens said asbestos bv itself did not seem to lead to can cer, but rather enhanced the ap parent cancer-causing properties of cigaret smoke. UCC 013101 A ; / rs -> r\ TU/ O Statement by George Vf. Wright, M.D., Head of the Division of Medical Research in the Dept, of Medicine of St. Luke's Hospital, Cleveland, Ohio . before U. S. Dept, of Labor, Occupational Safety and Health Hearing on Proposed Occupational Asbestos Standard Washington, D.C. March 16, 1972 UCC 013102 My name is George W. Wright. I am the Head of Medical Research in the Department of Medicine of St. Luke's Hospital, Cleveland, Ohio. In 1932 I received the MD degree from Indiana University School of Medicine. After five years of Post Graduate Training in Internal Medicine with special training in pulmonary disease I spent two additional years in research training in the Department of Physiology at Case-Western Reserve University. From 1959 to 1953 I was a member of the Saranac Laboratories of the Trudeau Foundation engaged in studies of the pneumoconiosis, including asbestosis. Since 1953, I have continued this general field of study in . my current position. . My statement will be confined to consideration of a single primary question. This question is: What is the quantity or concentration of asbestos, in the air breathed by those engaged in .the production, manufacture or use of asbestos products, which can be tolerated for a normally expected work life without risk that such exposure will cause disease? The answer to this question goes to the heart of these hearings. While the question is rather easy to formulate it is difficult though not impossible to answer. The obligatory information required for developing an answer to the primary question on an acceptable scientific basis is of two categories. One of these essential categories concerns the dose or quantity of asbestos inhaled and the other essential category concerns the biological response. What we need to learn is the dose-risk relationship. The dose is estimated in terms of concentration of respirable asbestos in the air multiplied by the duration of the exposure. It is obligatory that we establish a dose, in measurable terms, at which the biological manifestation of disease occurs and then, by observing populations exposed to progressively smaller and smaller doses, determine the level at which the biological reaction to asbestos no longer occurs. A ` 4072 UCC 013103 2. To make observations with regard to the various dose levels of different woi'king populations without knowledge of the biological response of these same populations is of no use in answering the primary question. To make observations of the biological response in various working populations without valid knowledge of the different levels of asbestos exposure experienced by these same populations is equally of no use for finding an answer to the primary question. Standards for a safe level of asbestos exposure proposed or set in the absence of reliable and valid data in both of these two categories must be considered empirical and to some degree arbitrary and should be recognized as such. I wish to indicate some of the difficulties encountered in efforts to obtain the information essential for determining what the safe level of asbestos in the occupational environment truly is. Asbestos is a generic term embracing four varieties that are in common commercial use. Of these, chrysotile is used in largest quantities followed by crocidolite, amosite and anthophylite. Each of these has different chemical and physical attributes. Some working populations are exposed to only one variety of asbestos while others are exposed to two or more simultaneously and in varying proportions. Thus there are several kinds of populations each exposed in quite different ways to one or more kinds of asbestos, each of which might react biologically in a different manner. Moreover, workers exposed to asbestos are further exposed simultaneously to other airborne agents. In production, manufactur ing and utilization processes these may differ greatly. For example, the asbestos producer is exposed to asbestos with minimal coexisting agents while, in contrast, the insulation manufacturer inhales asbestos plus silica plus other pneumoconiosis producing dusts. Insulation applicators inhale these materials plus a variety of UCC 013104 4 073 3. additional agents present in whatever the environment is in the place where he is . working at that tine. Attention to such coexisting agents has been ignored in studies of insulation workers. Variations of type of fiber and the circumstances surrounding their use must be taken into account in answering the prinarv question and would suggest the possibility that different standards night be rational in order to meet different conditions of use of asbestos. There are four, totally different biological phenomena or diseases thought to be related in some way to the inhalation of asbestos fiber. These are pulmonary fibrosis, bronchogenic cancer, thickening of the pleura, and mesothelioma. Not a single one of these diseases is peculiarly related to or caused solely by the inhalation of asbestos fiber. Each of these four diseases occurs "do no'vo" or for other reasons in persons who have never been exposed occupationally to asbestos. The fact is, the biological reaction attributable to asbestos is not a specific kind of disease induced solely by asbestos. Instead, the biological reaction to asbestos manifests itself by the fact that in some populations occupationally exposed to asbestos, there is, in contrast to nonexposed populations, an excess occurrence of one or more of the four previously mentioned diseases. To determine the safe level for the use of asbestos, we are required to demonstrate the level of exposure to asbestos at which no excess of disease develops when the exposed population is compared to a nonexposed population. In order to establish a safe level we must examine suitable control populations not exposed to asbestos, but age matched and residence matched, from which population one can learn the frequency of occurrence of the specific diseases in question. In addition, we must examine an exposed population, which can be ranked in various levels of exposure, in order to learn at what level an excess these diseases occur in the exposed population. UCC 013105 A ' 4074 . 4. The observation of a biological abnormality in only one or two persons who have been exposed to the inhalation of asbestos fibers does not permit a comparison to suitable control groups or afford contrasting exposure values. Such observa tions are of no use for determining a safe level standard. Isolated case reports of mesothelioma, brochogenic cancer or pulmonary fibrosis in individuals who may also have had an exposure to the inhalation of asbestos fiber are of no use in setting a safe standard for asbestos based upon sound scientific principles. Larger populations in which only the frequency of occurrence of disease is reported, without the necessary data indicating ranges of exposure and in which no' attempt to relate variations of exposure to disease is made, fall into the same nonusable category for setting a valid safe level. This is not to say that observations in such groups are of no value for other purposes, but the issue should not be confused by introducing data from such inadequate studies into considerations of safe levels of asbestos exposure. Suitable control populations^ made up of individuals in sufficient number who were never exposed to the occupational inhalation of asbestos fiber and occupational groups whose exposures are demonstrated to have wide variation are difficult to obtain but absolutely essential for our purpose. The absence of this kind of control data, excused or overlooked on the basis that it cannot be obtained, is an unacceptable condition if the safe level standard is alleged to be set on the basis of universally accepted scientific principles. There is difficulty also with assessing the frequency of occurrence of the diseases thought to be related under some circumstances to the inhalation of asbestos fiber. There is disagreement as to the criteria for a valid diagnosis of mesothelioma. The criteria for a diagnosis of "asbestosis," especially in its least severe manifestation, are not generally agreed upon. The use of the chest X-ray for (diagnosing the early manifestation of asbestosis is a case in point. A recent report by Murphy and his co-workers of a study of employees in a shipyard demonstrated that * ' * A : '+ 0 7 b UCC 013106 5. twenty percent of the control, or nonexposed population gave evidence of X-ray abnormalities which, if-observed in the exposed population in the absence of controls, in all probability would have been interpreted as being evidence of the effect of the inhalation of asbestos fibers. In a population which has been exposed to asbestos inhalation, it is very tempting to ascribe any departure from a perfect appearance in the chest roentgenogram to the occupational exposure, and indeed, in some studies this has been done. It is imperative to recognize that some persons who have never had an occupational exposure to asbestos will show the same X-ray shadows that have been interpreted by some as evidences of asbestosis in populations exposed to the. inhalations of asbestos fiber. Studies such as those by Murphy et al exemplify the necessity of having suitable controls included in epidemiological studies bearing on the determination of a safe standard for asbestos. There are still other difficulties having to do with establishing the dose-risk relationship. The health effects of asbestos inhalation are both dose and lapse-time related. Overt evidences of asbestosis do not appear until years after the initiation of the exposure. The interval between onset of exposure and its effect is even greater for the development of bronchogenic cancer or meso thelioma. This interval ranges between twenty and forty years. Because of the long time lapse between the initiation of exposure and the manifestation of injury, the incidence of disease occurring in populations now under study is the result of, and must be related to, exposures which took place twenty to forty years or more ago. To relate exposure measured only in the past five or so years to the current frequency of development of disease which actually was induced by exposure occurring years earlier, is a serious error. During the past twenty-five to thirty years there have been many technicological changes in the production, manufacture and use of asbestos UCC 013107 A' / O -7 . tUj 0 6. containing material. In many situations there is much less asbestos now being incorporated in the material than was true twenty or more years ago. In addition, there has been a progressive dust control effort to reduce the concentration of airborne asbestos in mines, mills and manufacturing establishments in a deliberate attempt to reduce and abolish asbestos related disease. So much has been accomplished in this direction by technicological change and systematic asbestos control efforts, that contemporary measurements of occupational environments cannot be accepted as representative of conditions twenty to forty years ago. To summarize this part of my statement I strongly urge that when data offered in support of setting a safe level standard is being judged, one should ask the following questions: 1. What were the different kinds and proportions of asbestos used and what were the coexisting agents to which workers were exposed in the different occupations? 2. What were the specific criteria and methods used, and were they adequate for making a diagnosis of the biological . reaction attributed to the inhalation of asbestos? 3. Were suitable controls in the sense of nonexposed populations and exposed populations whose exposures varied in intensity and duration utilized? 4. Was the exposure which was actually responsible for the disease properly determined or were contemporary dust estimates inappropriately applied to disease which was in fact the result of exposure years ago? UCC 013108 A'4 The demands inherent in these questions pose formidable obstacles ' to arriving at a scientifically valid single number which will indicate the concentration of occupational airborne asbestos that can be tolerated with safety for the customary duration of employment. In spite of this, as I will show later, there are substantial data which will satisfy the requirements posed by these questions and which can be used for the purpose of determining at least a first approximation to the safe level of occupational exposure to airborne asbestos. V.'e must now examine the various established and proposed standards for a safe level of asbestos in the occupational environment, in the light of the just discussed requirements as to data needed for setting a standard on a sound scientific basis. Systematic efforts to reduce the amount of asbestos in the air of working places by governmental directive was made in the factories of Great Britain beginning in 1931. No numerical standard for this purpose was set, but Statuatory Rules and Orders were promulgated. Later, on the basis of limited data relating impinger dust counts to X-ray abnormalities in several asbestos textile factories of the USA, Sayers and Dreeson suggested a numerical standard of five mp/ft as a tentative safe level. This was the limit adopted by the American Congress of Governmental Industrial Hygienists in 1946. Utilizing the conversion data for textile mills published by Lynch and Ayers of the U. S. Public Health 3 Service, five mp/ft is the equivalent of approximately thirty fibers/cc. In 1968 the British Occupational Hygiene Society suggested numerical guides aimed at reducing the risk of developing asbestosis. The suggested guides indicate that those concentrations, averaged over a three month period below 2 fiber/cc ought to be considered low, and that over the course of 50 years of employment, 100 fiber years is the level below which there would be less than a 1% chance of developing asbestosis as defined chiefly by the presence of rales. A ' 40 UCC 013109 8. If asbestosis is defined by X-ray abnormality, the level becomes 135 fiber years. .3 In 196S the ACGIH changed its recommended standard to a TWA of 2 mp/ft , or twelve fibers/cc. In 1970 this Committee decided to change the standard to 3 5 fibers/cc, which is equivalent to less than 1.0 mp/ft . Several months ago OSHA set an emergency standard of 5 fibers/cc, and within the past few days NIOSH now proposes a standard of 2 fibers/cc. What is the scientific basis for these various standards? The standard proposed by Sayers and Dreeson did attempt to relate dose of dust containing .asbestos, as measured by the midget impinger to the risk of developing pulmonary abnormalities in terms of abnormal X-ray patterns. Their study showed a higher frequency of abnormal X-ray patterns in those most heavily exposed as contrasted to those less exposed. They found no excess of abnormal chest X-ray patterns in - 3 - those workers exposed to less than 5 mp/ft . Hence their suggested standard of 3 5 mp/ft . We now know, however, that the population studied was not observed long enough for the full range of disease to develop. The authors appreciated this possibility and proposed the standard as being a tentative one. In retrospect we know that the standard, although it led to marked lessening of the dustiness in some occupations, was not adequately based and the passage of time has demonstrated it to be an inadequate standard. The numbers proposed by the British Occupational Hygiene Society are based on a study of 290 male employees from a single asbestos textile mill. Their employment began after 1933, all had worked for at least ten years, and the exposure period extended from 1933 until 1966. The indicator of disease vras basal rales and X-ray changes. No measurements of dustiness in this mill were available prior to 1950. Membrane fiber counts done in the modern manner were used only in the last year of the study and these served as the factor for converting previous counts using A ; 4073 UCC 013110 9. other methods to an expression in terms of fibers. To obtain an index of exposure for the period between 1953 and 1950 - a crucial period of exposure the first measurements made in 1950 were raised by 50%. . No evidence was given for using this very slight augmentation. Studies in other textile factories such as those by Sayers and Dreeson indicate that when ventilation controls were fii'st applied in their textile mills the dust counts dropped 1,000% or more. One would assume that the same happened in this British textile mill. The seventeen years of exposure during that most crucial period between 1933 and 1950 would appear to have been substantially underestimated. This study, in spite of its less than adequate scientific base is important because it was the first attempt after 1938 to set numerical guidelines for the .prevention of asbestosis. The number of persons in the study is very small; the criteria for disease, especially basal rales, not universally accepted; and the estimate of dustiness seriously lacking in rigor. -The estimate of dustiness was on the low side for the reasons that I have already mentioned and, in addition, because no attempt was made to further adjust for the longer working hours and hence of exposure during the war and earlier years. In spite of all of this, the study is a first approxima tion to a solution of a problem for which there were essentially no other available data in 1968 upon which to attempt a dose-risk estimate. It is my understanding that the enforcement agency of Great Britain looks upon these standards as guide lines and not as rigid requirements for all circumstances in which asbestos is used. Thus, they recognize the incomplete nature of the data used in developing the numbers. UCC 013111 A 400C 10. The lowering of the 193S standard from 5, to 2 mp/ft^ and 12 fibers per cc, adopted by the ACGIH in 196S appears to have been based in part upon the data underlying the British proposal and also upon the fact that there was a grow ing awareness that the old standard of 195S was not universally effective. The further lowering to 5 fibers/cc was not based upon new scientific data, but appeared to have been made to establish a margin or "factor of safety In a personal communication from Dr. Herbert Stockinger, Head of the Division of Laboratory and Criteria Development of the National Institute of Occupational Safety and Health and Chairman of the Committee on Threshold Limit Values of the American Conference of Government Industrial Hygienist, I am informed that four months ago, in November of 1971, the Committee of the ACGIH reviewed the standard of 5 fibers/cc and found no evidence to indicate that it should be changed. There are several relatively current studies which support this decision. . I would now like to discuss five of these supporting studies. Murphy et al, in December of 1971 published data on workers exposed over a period of approximately thirty-five years as pipe coverers in new ship construction. The authors demonstrate that no evidence of asbestosis was found until at least 60 million particles per cubic foot years of exposure had been exceeded. This would indicate that for a forty year period of employment, 1.5 million particles per cubic foot would be the value below' which no asbestosis occurred. The report indicated that the actual occurrence of asbestosis was restricted almost solely to those exposed to more than 75 million particles per cubic foot years, which would be close to a value of 2.0 million particles per cubic foot for those employed for forty years. Utilizing a conservative number to convert particles to fibers per cc, one arrives at a level of 5 or more as being that below which no asbestosis was observed. If one utilizes their konjmeter data, one can, by suitable calculations. UCC 013112 11. estimate that the average exposure for these workmen was in the neighborhood of 8 fibers per cc, and this too would suggest that a number of 5 or more fibers per cc would have been the level below which no evidence of asbestosis developed. This study indicates, not only that the old standard of 5 mp/ft-5 is unsafe but also that a standard of 5 fibers/cc will prevent asbestosis in employees working for forty years or more. An extensive and detailed study of a population comprising thousands of workers in the mining and milling of chrysotile in eastern Canada conducted over the past few years by Dr. Corbett McDonald and his associates is of great importance in our considerations because this study has dust counts going back many years and chest roentgenograms available from'approximately 1935 to date. Dr. McDonald will report on these studies at these hearings. It is my understanding that these studies support the conclusion that those individuals exposed in these occupations for forty or more years would have to be exposed to higher than 6 fibers/cc in order to reveal any' evidences of asbestosis. Becklake and her coworkers, utilizing a segment of the population from McDonald's larger study'-, have demonstrated that in those individuals who have been employed for long periods of time in the mining and milling of chrysotile asbestos and who do not even show evidence of X-ray changes, the accumulated exposure must 3, have been more than 110 mp/ft y'ears before the most sophisticated techniques can detect evidence of those physiologic changes thought to develop in response to inhalation of asbestos. These data suggest that something larger than 2.5 million particles per cubic foot over a forty year period can be tolerated without even the most subtle manifestations of asbestos exposure. This number would translate into something between five and 10 fibers per cubic centimeter. UCC 013113 12. In the fall of 1971 at the Fourth International Congress on Pneumoconiosis, held in Bucharest, Dr. McDonald updated his previously reported large study and reaffirmed that an excess of bronchogenic cancer did not occur in the workers in mining and milling of chrysotile asbestos until an exposure equivalent to 200 million particles per cubic foot years was exceeded. This translates into 5 million particles per cubic foot for forty years. It indicates that in the mining and milling of chrysotile an excess of bronchogenic cancer would not be demonstrable in those individuals who were exposed to less than 5 million particles per cubic foot. This is equivalent to 10 or more fibers per cc. This most important finding supports the view held by Steward and others that an excess of bronchogenic cancer occurs only in those who have manifestations of asbestosis and.that the standard adequate to protect against bronchogenic cancer is a larger number than that required to.protect against asbestosis. ' Recently, Enterline, and his coworkers have reported the results of a study of retirees employed in various asbestos-using manufacturing processes including textiles and where the exposure was different from that in mining and milling because of the inclusion of exposure to crocidolite and amosite as well as other agents which might coexist. This study shows, and I quote "there appeared to be no direct relationship between asbestos dust exposure and respiratory cancer below 125 million particles per cubic foot years. Important increments in respiratory cancer mortality apparently occurred somewhere between 100 and 200 million particles per cubic foot years' exposure." This would indicate that exposure to 3 million particles per cubic foot would be tolerated for a forty year r>eriod without a risk of excess bronchogenic cancer in these types of occupations. Using the conversion factor suggested by Lynch et al, this is equivalent to IS fibers/cc. A z+ nu u UCC 013114 13. This series of studies indicates that a lower standard is required to protect against pulmonary fibrosis or asbestosis than to protect against bronchogenic cancer. These five studies offer strong support for the position taken by the American Conference of Governmental Industrial Hygienists that there is no need to lower the standard below 5 fibers/cc in order to protect against pulmonary fibrosis or bronchogenic cancer. In my judgment we have no specific information of a suitable scientific nature expressing the dose-risk relationship for mesothelioma. Isolated case reports of mesothelioma are of no value in establishing a dose-risk relationship. Equally useless for this purpose are the data offered in studies of insulation workers, asbestos miners and millers, workers in asbestos using manufacturing, domestic exposures and neighborhood exposures. Not a single one of these studies offers data comparing variable exposures to the incidence of mesothelioma and they are therefore of no use for establishing a safe level of asbestos in the occupational environment. These studies do indicate that in some circumstances the risk is present but none speak to the question of the safe level on scientifically acceptable grounds. Nevertheless, these studies of larger numbers of cases of mesothelioma suggest that, in some circumstances the exposure to asbestos which may be related to the development of mesothelioma might be less than that required to produce asbestosis or an excess of bronchogenic cancer. One factor, which has been demonstrated with respect to the relationship between meso thelioma and inhalation of asbestos is of the utmost importance. In all of those circumstances where a strong relationship between mesothelioma and the inhalation of asbestos is suspected, two varieties of asbestos, namely crocidolite and amosite, invariably have been implicated either alone or combined. This is the case in the excess occurrence of mesothelioma among crocidolite miners, asbestos using insulation workers, workers in asbestos textile and insulation manufacturing and in a large A i 4084 UCC 013115 14. nultiproduct asbestos using manufacturing plant in the USA. In most of these circumstances there has been a mixed exposure and chrysotile has also been present. In striking contrast, however, when exposure has been solely to chrysotile, as in mining and milling of chrysotile, the frequency of occurrence of mesothelioma has either not been increased or increased only to the very slightest degree. The virtual absence of an excess of mesothelioma in populations exposed solely to chrysotile has been reported by Gilson, Vigliani, Wagner and McDonald on the basis of separate studies. With respect to anthophylite, no excess of mesothelioma has ever been reported. On the basis of information currently in hand, therefore, mesothelioma appears to be predominantly linked with exposures to crocidolite or amosite but the dose relationships are unknown. The studies referred to thus far are the only ones that I am aware of which in my judgment have a meaningful bearing on the setting of a standard for control of asbestos exposure. Other data does exist but in my judgment it does not conform to those criteria, universally agreed upon, for a sound scientific basis upon which to predicate a safe standard. There is an abundant other body of data which indicates that the prolonged inhalation of asbestos fibers above some level is hazardous, that the biological effect is dose related but that many of the workers exposed for a life time never do develop asbestos related disease. This data indicates clearly that past exposures in some occupations, as for example the mining and milling of chrysotile were far less hazardous than exposures in asbestos textile manufacture or the insulation workers' trade and possibly in other occupations as well. The reasons for these differences arc not entirely resolved at this time. Until recently the insulation trade uses much more amosite than chrysotile and in some work, especially in lingland, large amounts of crocidolite have been used. There UCC 013116 7/ Oij U ^O 15. are coexisting agents in the insulation trade which are not present in mining and milling of chrysotile. The peak exposures appear to be much higher in the insulation trades than in mining, milling or manufacturing. Peak exposures may be much more hazardous than lower levels of prolonged exposure. Fiber counts in the insulation trade in shipbuilding in Great Britain and in construction in Finland ranged from twenty to hundreds of fibers/cc depending upon the kind of work being done. Fiber counts in the construction industry in this country currently indicate somewhat lower TWA levels but intermittent high peaks of exposure. For example, during the mixing of asbestos cement, dust counts commonly as high as 75 fibers/cc during a 5 to 10 minute period are reached as often as 5 times or more a day. Unfortunately, there are no data in the insulation worker trade that compare degrees of exposure over a period of many years to the biological manifestations of excess disease. Until this is available, there is no way of utilizing data from these trades to establish a standard for the control of asbestos inhalation. ' There is every indication that the levels of exposure should be lowered, especially the peak levels, but whether or not a lower TWA standard is needed in the insulation trade than in the other trades remains unsettled. There is sub stantial reason to believe that crocidolite and amosite should be controlled more stringently than is chrysotile. There is also reason to believe that the geometric conformation of the fibers in the mining and milling of chrysotile may be different from those fibers generated subsequently in manufacture and use of asbestos. Moreover, the fibers of crocidolite and amosite even in mining have a different geometric configuration, as actually observed by Timbrel1 in airborne specimens, from that of some forms of chrysotile. For these reasons the pulmonary retention of chrysotile may be substantially less than for other varieties of asbestos or for the kinds of fibers generated in other occupations than mining and milling. experiments have demonstrated this to be true. Animal A < 4Q8Q UCC 013117 16. On the basis of data now available and adequate for the purpose, I wish to indicate that in my judgment a standard of five fibers/cc TWA with peaks not to exceed 10 fibers/cc, such as recommended by OSfLA in its present standard and by the ACGIH constitutes a level which will protect against the development of asbestosis and bronchogenic cancer and includes a safety factor since it is a level substantially below that which has been demonstrated to be associated unequivocally with an excess of these two abnormalities. There is evidence relating crocidolite and possibly amosite to excess mesothelioma which suggest that a more rigorous control of amosite or crocidolite would be justified. For this reason it may be rational to have different standards covering different occupations depending upon the variety of asbestos used. ' Since I am in disagreement with the recommendation of the Criteria Document that two fibers/cc be established as the safe level of occupational airborne asbestos, it is incumbent upon me to indicate the important points of mv disagreement. In my opinion it is incumbent upon the authors of the Criteria Document to present evidence, which will meet the requirements for scientific validity, in support of their proposal to change the standard and to establish a new one. In the entire document I do not find reference to a single study containing data which will, on the one hand meet the criteria of scientific validity for setting standards and, on the other, support the need to change the standard from 5 fibers/ cc or to set it at 2 fibers/cc. In fact, the Criteria Document explicitly says on page 10 of Section 5 "The number of studies that have collected both environ mental and medical data and with a significant number of exposed workers, is not sufficient to establish a meaningful standard based upon firm scientific data." UCC 013118 A 14087 17. In other words, the authors of the Criteria Document do not provide any scientific data upon which to base their proposal to change the standard from 5 to 2 fibers/cc or to support the choice of a standard of 2 fibers/cc. The failure to provide this support, in my judgment casts the most serious doubts upon the validity of the proposals. I am in complete disagreement with the Criteria Document with respect to its expressed opinion that the data relating exposure to biological reaction is inadequate to establish a meaningful standard at this time. While the evidence may not be as far reaching as we would like, it is scientifically valid-and adequate to support as a first approximation the opinion that the present standard, established by OSHA several months ago at 5 fibers/cc. TWA and peaks not to exceed 10 fibers/cc should not be lowered but left as it is. I have cited the studies supporting this opinion. Lacking dose-risk relationship data adequate to support the proposal of 2 fibers/cc, the Criteria Document appears to promote an aura of extreme toxicity of asbestos fibers in order to justify the new level. This is done chiefly by citing isolated case reports. In my judgment an inordinate amount of weight is given to isolated case reports which, though of interest and some importance, have no possible utilityin setting a numerical standard. Their use in the Criteria Document is doubly difficult to accept in view of- thefact that on page 24 of Section III there is the following statement "Isolated clinical case reports are difficult to interpret in terms of dose-time response relationship and can only be used to indicate other possible problem areas and to highlight what may prove to be practicable areas for further study." UCC 013119 k q/- OU o0 AO 18. An attempt to convey the implication of extreme toxicity of asbestos is again made on page 7 of Section 5 by reference to a study of 232 former employees in a plant that manufactured insulation. This study, by Selikoff, is quoted as revealing four employees who developed X-ray evidence of asbestosis after only one day of exposure to asbestos. Observation of a control group for comparison to those who had been exposed, is totally absent from the Tables for this study that are shown in the Criteria Document. Murphy's study of pipe- coverers, referred to earlier in this statement, demonstrates beyond doubt that in any adult population not exposed occupationally to asbestos there will be some individuals with X-ray shadows that could be interpreted as evidence of slight asbestosis. In the absence of suitable controls, Selikoff's study cannot, on scientific grounds be interpreted to prove that one day of exposure to asbestos causes asbestosis. To do so on the basis of the data shown is epidemiologically unsound and to cite this study as evidence of extreme toxicity of asbestos is completely unwarranted. ' . The manner in which reports and data of different investigators throughout the world are utilized and criticized does not appear to be uniform in this document. For example, the comprehensive review of the epidemiology of asbestos related cancers by Wagner et al, published in 1971 is not referred to. The report by McDonald et al, of an extensive epidemiologic study relating dose to risk in 11,78S workers employed in the Quebec chrysotile asbestos mining industry is not discussed in the Criteria Document. This study,published in June, 1971 is the single most detailed and complete study in the world's literature of the dose-risk relationship of one kind of population exposed to airborne asbestos. The only reference made in the Criteria Document to this study, pages IS and 20 of Section 5, is a criticism of a "progress report" given by McDonald at the Bucharest meeting in September of 1071. One would think that a study of this magnitude iw^u^'.o UCC 013120 19. require discussion in a document intended to be a fully developed presentation of the evidence supporting recommendations of such great importance. It is difficult to understand why McDonald's report is criticized, as stated at the too of oage 20 of Section 3, because of the conversion of numbers of particles to numbers of fibers. Particles are converted to fibers by the British Occupational Hygiene Society in developing their standard and at no place in the Criteria Document, pertaining to the British recommendation, does one see a questioning of that procedure. If it is acceptable in the one circumstance it should be acceptable in the other. . It is even more difficult to understand the criticism expressed in the last sentence of the 1st paragraph on page 20 of Section 3 to the effect that the McDonald study lacks the evidence necessary to make general comparisons with the data of other reported work. The published paper by McDonalds' group contains the complete biological data and the required exposure data expressed in mp/ft5. This is substantially more data than that furnished by others since it relates exposure to biological effect in the same population whereas other studies such as those of insulation workers do not in any way provide this corelated data. The index of dustiness used in the McDonald report is the same as in those of Murphy et al, Decoufle-Enterline and Williams, all of which are quoted in this document. The .criticism that McDonald did not indicate the details of the method 3 used for converting particles/ft to fibers/cc could easily have been answered by a letter or a telephone call, if the authors of the Criteria Document had been desirous of making the comparisons. UCC 013121 A 4- 0 G c 20. Much weight is given to an unpublished paper by Williams, et al from the Pennsylvania Department of Health. One wonders why, in such an important document as the N'lOSH Criteria Package, the crude data of the Williams' study was not shown in the tables of the Criteria Document. The way in which the sixty-four cases of asbestosis referred to were related to what was undoubtedly a variable exposure is not shown. It is very probable that all of these 64 cases occurred in those who were most highly exposed, very possibly in the neighborhood of five million or more particles per cubic foot. The failure to handle such data in the conventional dose-risk relationship is a serious error. Inordinate and unwarranted attention is given to contemporary dust counts. The impression is given that these present day counts represent the conditions that existed over the past 40 years. While this may not be intended, more care should have been taken to indicate that the counts were substantially higher in the past, especially in manufacturing places where effort toward con trolling exposures by exhaust ventilation, etc. has been expended in the past 30 years. In addition, the reduction of the amount of asbestos contained in manufactured materials has further reduced the exposures, particularly in asbestos insulation workers. Most of the counts in the tables of this document are expressed as averages, as for example. Tables 13 and 14 pertaining to exposures of insulation workers. This is an inadequate way to display data, since it can give misleading information by masking high exposures if there are a large number of low exposures to dilute the high ones. Biological effects are much more likely to occur in those persons heavily exposed than in those with low exposure, thus, averages of all exposures have little meaning or use in determining the dose-risk relationship. UCC 013122 A /t nU nv> 21. It is not possible to evaluate fully the exposures from the data shown in some of the Tables of this document. For this we need to know not only the TWA's but also the peaks, then number of observations and the conditions of the environment during the time of sampling. This criticism is especially pertinent to the exposures of insulation workers shown in Table 14. The insulation worker experiences great variability with respect to job conditions, to a large degree dictated by the volume of the space in which he works and by natural ventilation as well as the kind of work he is doing at the time. Dust counts under all sorts of conditions, and peak as well as TWA exposures must be measured before the insulation worker's exposure can be portrayed. With respect to Table 14, it is surprising that the job of ."cement mixing," notoriously characterized by peaks of exposure as high as 75 fibers/cc for periods of 5 to 10 minutes several times a day, is omitted. The summary, on page 16 of Section 5, describing the basis for the new standard recommended by the Criteria Document is confusing and inconsistent. I quote from the second paragraph, "evidence indicates that past and current standards for fiber concentrations in the working places where asbestos fibers occur, though undoubtedly contributing to reduction of the severity and frequency of asbestosis, have not provided complete protection from exposure to asbestos, necessitating development of a new standard." There is evidence that asbestosis developed under some circumstances, in places thought to have an average exposure of five million particles per cubic foot, or in modern parlance, thirty fibers/cc. This was the standard set in 195S. The ACGIIl created a new lower standard in 1968 and another still lower, introducing a safety factor in 1970. UCC 013123 A 4 002 22. The British Occupational Hygiene Society suggested numbers that might serve as a standard in 1968. The current standard in the USA set by OSHA is five fibers/cc, and was set only a few months ago. If there is to be a new standard it will be one set since a few months ago, or at most, set since three years ago. The statement in the Criteria Document, to which I have just referred, indicates that the authors have evidence that the standard recommended by ACGIH in 1968 has been inadequate and has not provided complete protection and hence a new standard is needed. The authors of the.Criteria Document should be required to give that evidence and it is obvious that they have not. Could it be that they are referring to the fact that the standard set in 1938 is inadequate and that a better standard is needed? If so, a lower standard was provided in 196S and still lower in 1970, and it is this standard which was promulgated as an "emergency standard" by OSHA. It is this OSHA standard for which I believe there is substantial factual evidence of a supportive nature. An even more serious inconsistency is demonstrated on page 16 of Section 5. Close examination of Items a, b, c, and d reveals in unequivocal terms, that in the judgment of the authors the Criteria Document there are no scientifically usable data on which to base a standard. Nevertheless, without such data they decide that the current standard must be changed and moreover recommend precisely what the new one should be. There is a strong inference . from the second paragraph of page 17, Section 5 that one and perhaps the chief reason for setting the recommended standard at two fibers/cc is that the British have recommended such a standard. I disagree with the concept, if actually intended, that this represents a scientifically valid reason for recommending such a standard. Moreover, it is my understanding that the British did not set a standard in the same sense that it is intended to be used under the new Occupational Safety and Health Act. The British Standard is a scries of numbers A;4003 UCC 013124 23 proposed to furnish a guideline with a wide range of personal judgment on the part of their inspectors as to the need for corrective measures when these numbers are exceeded. Under our act it is my interpretation that a standard is to be set which, if not complied with, places the operator under certain penalties. To my mind the two conditions are utterly different. UCC 013125 A 24 SUMMARY In this statement I have described the kind of data required for characterizing the dose-risk relationship in such a manner, that it can be used for setting an occupational standard for airborne asbestos on a scientific rather than an arbitrary basis. Because of the difficulties described, much of the data now extant, concerning asbestos associated disease, is of no use for setting a standard. Isolated case reports and data giving exposures or bio logical effects without relating the two in the same population are examples of this kind of unusable information. Unfortunately, much of the data now available is competent only to say that asbestos is more or is less hazardous in different groups and that the exposure is varied. Nevertheless, although not numerous, there are specific data competent to speak to dose-risk relation ship and these can be used for our purpose. I have cited these. I have indicated the reasons for my opinion that the Criteria Document has failed to do that which is incumbent upon it, namely, to provide sound scientific evidence to support their request for a change from the OSHA emergency standard and for a new standard of 2 fibers/cc Tl'.'A and peaks not to exceed 10 fibers/cc. . I disagi'ee with the view of the Criteria Document that there are no scientifically obtained data adequate for the purpose of setting a standard. I have cited the studies which I believe are scientifically valid and adequate for setting a first approximation to a standard or safe level of airborne asbestos in occupational environments. In my opinion, these studies fully support the current OSHA temporary standard of 5 fibers/cc TV.'A with peaks not to exceed 10 fibers/cc, and the recent decision of the ACGIH that there is no need to change from this A ; 0 n o^ UCC 013126 25. standard. It should be emphasized that prior to 1940 and for some years thereafter, when many of those persons now developing disease were actually- being exposed, the dust counts in mining, milling and manufacturing commonly were in the range of 10 to 100 mp/ft-5. This was most likely equivalent to 30 to 600 fibers/cc. There is no evidence that exposures during that period for insulation workers was substantially- lower and, on the basis of British and Finnish data, it was in that range. It is clear then, that the curent OSKA temporary- standard represents a tremendous reduction from the dust levels of previous y-ears and, in my opinion, includes a substantial safety factor.' I believe this level will protect workers, using asbestos over a forty year or more span of employment, from developing asbestosis or experiencing an excess of bronchogenic cancer. If crocidolite and perhaps amosite are more stringently controlled, the liability- of experiencing mesothelioma will be markedly- reduced and probably abolished. . UCC 013127 fcRp3R7 SERIES gw CSHfl* CTuWE 2Gil?72- Froiii OSHA to the Arbestcs Industry . . . a new parmonsnt standard The truth is that OSHA and the Secretary Labor in setting this standard have''shown courage a: wisdom, that certainly is too seldom recognized ai Six months to the day after the Dec. 7, 1971 imposition of a temporary standard, in accordance with the Occupational Safety and Health Act of 19"0. the Secretary of Labor issued a permanent standard for exposure to asbestos fibers. * The asbestos industry breatlicd a sich of relief; it felt it could exist with tins standard. It is too early to estimate the cost of compliance to the industry or the effect cn sales of asbestos pro ducts, but it probably will not st'ii! the controversy. There are those who ?ec:n to force: that the nurnose of the asbestos standard. as wei! as Q5i i A itself, is to protect the workets. not to punish the industry. Effective July 7, 1972 the 8-hour time weighted average (TWA) airborne concentration of asbestos fibers to which any employee may be exposed shall not exceed 5 fibers, longer than 5 micrometers, per cubic centimeter. Effective July 1, 1976, the 8-hour TV,'A will be dropped to 2 fibers per cubic centime ter. ' . . commended. ' " The other parts of the standard are of cqu Importance to the health of the workers, and :h; also affect the financial condition of the industry. Labeling of asbestos and asbestos contnlnn products has become to some a "cause celebre" muc as the labeling of cigarettes. Botii NIOSH and ti Advisory Committee on Asbestos Dust recommend; labeling which contained words such as "dauge: and "cancer" for all asbestos-containing product The new standard r-eOjUires a label . CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATH!.'.\' n * c r* E ST OS DUST MAY CAUSE SERIOUS BODILY HARM _ This lab-el is not required where the asbest libers have been modified by a bonding agent, cor, ine, binder, or other material so that d urine auv for seeable use it can become airborne, ' Most medical opinion has been divided between Recognition was given in writing the standard : ' 7 - fiber and the 5 - fiber standard but not cn the sound engineering principle that protvctic tiiu clanger of exposure to asbestos of high enough in against asbestos fibers is best obtained by control's!: tensity and long enough duration. Because of the lor." lapse in time, between onset of exposure and biologi cal lnsnli'eslatic-n.s. an accurate measure of exposure, of 20 or-?Q vea:s a-co is not known. Thus, sreculor tier, rather than solid evidence has given rise to the dire warnings,. - . .The conflict in memcai evidence was resolved in favor of maximum rrotectlcn for the worker but with r four year transition period to allow employers to make the necessary changes to meet the more strm. pent standards.Beyond a doubt there would be few operations the: could meet a 2-fiber standard without. the `dispersion of released fibers in the worknia; Thus, respirators and shift rotations can be used cn as temporary expediencies until proper engineer! of equipment and sound work practices can be set as a means of standards' compliance. . * Additional complications are introduced in the establishment of a single standard that applies both manufacturing of asbestos and asbestos promt, and tire use of asbestos in construction. Tire strata:: applies to ai! varieties of asbestos cud workplaces differing amounts of hazardous exposure. the rillowc d t:a iiio: : period . I t is also the judgment of ih,e Sec ret.try ft...* no har:n i s re.son ably expected Tire Federal Register of June 7, 1972 emeu and adds to Section 1910.93. All parts of the p o' suit fr om e vr - * * re durtn g i he tiran.s icior.al period. posed standard have been covered in tire new stand. Hove, t.l :e N ew York T`ime:s. in a sliort article on June 6 t it! ed \.-vv.<k os Co de Kept Despite Warning" foil t!hat it shoe id : a "cheap shot" including: rer::iiss:d:e concentrations of ashore? be;s; methods of comoliau.ee: war nine si-ins: rucJi. examinations ana record keep me. at OSHA uuc1 the S'crctj rv of Lab or. F.v-.m die An objective conclusion is that the new p Wall St re et J v"M ;r*' *1! in its rem: >; ee article of June 7 fa b. ti: :or:.`i:v It coni k\ :::e iri'rn tise r v.'s>:.o; r ^ i re::; ti ;C >!- *. * * c*i i.ic manent tecticn siftanedaachrdasnwdworilkilfeprtrhoweviidlele;po.iwbpslooervrkvceerrss:twhheilelalth p he::e the Jo. * :at t .porter fa ItS l o r-.:::iiee that ass-eslc-. in b I":c lini :::.S cila .. * ias i: 4 C - ' .`m'.'-ry rds. /a HOC.7' heat of f:iictin: : to fa ; less let i'l! 1 Fo :te. to his final r monitorin'.: ar.d medical naca::.tc\' of 20,0 JJ n '..n `1 noli v. l\S **C"i1* worked V <ihi't cc`.till ic*r v \ y veil..Hi :e;e:s to the CO:*.: litre!: on iIt 4' 1. . ^ . .;y :hu to ti: e i: lanufact.i: i::g. tions that .mo awn'cMe to OSHA. N10S11. p.loycc and his representative, and to the emu!.-; pu vide a system of checks and balances that -h-. tei:....it ion., h-:n V.,.is ti: Ley. i; ot .mcurac V. UCC 013128 make the results of the st.mdau! comnli.mvo c!.v. XJ 1-- . I 1 J VI }JUK Ap, q a. i^i^nnv o T-W A T Tfl .</ (- V - b <y <=>* e<oS' e* rrLc*-riilstion jlLj Jl JL G AjLLs.OJLJ JL JL1 a LS'U J r>r-'! f U:i ij Economics Medicine Technolory Bi-v/eekly business newsletter published from the Nation's Capital Leonard A. Eiierer EdilCrt" corf Pvhlithtr Business Publishers. Inc., P.O. Box 1057, Biair Station, Silver Spring, Maryland 20910, (301) 5S7-53C0. Subscription Rate: $50 per year, $35 for six months U.S., Canada and Mexico; $70 per year in all other countries (includes air mail postage). Multiple copy rates on request to Henry E. Kleiner, Jr., Business Manager. Vol. 2 No. 15 July 17, 1972 Page 141 SLANTS & TRENDS FIRST YEAR PERFORMANCE of Occupational Safety and Health Administration will be probed by Senate Labor & Welfare Committee in oversight hearings scheduled for July 25-27. Congressional critics will testify July 25, followed by OSHA officials the next cay. OSHA ADMINISTRATOR GEORGE C. GUENTHER stressed Nixon Administration's opposition to exemption of small firms from Federal Job Safety Act, as voted by House and Senate last month (JS.SHR, July 3, 1972, p. 131), at press ' conference July 13. Some of most hazardous work can be in small firms, he noted, promising to ease record-keening bur den for small employers. Instead of arbitrary limit on size of company affected, he suggested Secretary of Labor should be given authority to exempt certain employers at his discretion, thus allowing. OSHA to concentrate on worst problems first. NI0S H PLAN'S TO ISSUE CRIlERIA DOCUMENlS before end of September recommending standards''' r occupational exposure to cotton dust, ultraviolet radiation /"silicaT) mercurv, bis (chlorom.ethyl) ether. Under development for later issue are criteria on senzeae, lead, trichloroethylene, parathion, cadmium, fibrous glass, chromic acid, arsenic, toluene, sulfuric acid, and sulfur dioxide. Document on noise is expected momentarily / DEMOCRATIC NOMINEE SEN. GEORGE KcGOVERN has proposed an 8-polnt program on job safety and health, inducing a call for 8,000 Federal OSHA inspectors, plus 4,000 industrial hygienists; full access for workers to complete results of Federal inspections; funds for industrial safety and health training for employes so they can serve as own in spectors; priority cn research for new techniques in removing hazards. OSHA now has about 400 compliance officers and inspectors. UCC 013129 RULES AND REGULATIONS Title 20--LABOR Chapter XVII--Occupational Safety and Health Administration, Depart ment of Labor PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Standard for Exposure to Asbestos Dust On December 7, 1971, an emergency temporary standard concerning exposure to asbestos fibers was published in the Federal Register (3G F.R. 23207). In ac cordance with section 6(c) (3) of the Williams-Steiger Occuptaional Safety and Health Act of 1970, a nolice of proposed rulemaking regarding a permanent standard for exposure to asbestos fibers was published in the Federal Register on January 12, 1972 (37 F.R. 466). The no tice invited interested persons to submit both orally and in writing, data, views, and arguments concerning the proposal. On or about January 24, 1972, the Ad visory Committee on Asbestos Dust was established and requested to make writ ten recommendations with regard to the proposed standard on asbestos. On or about February 1. 1972. the Department of Health. Education, and Welfare trans mitted to the Secretary of Labor a cri teria document containing Recommenda tions for an Occupational Exposure Standard for Asbestos by the National Institute for Occupational S-.- ty and Health (NIOSH). Public nonce was given of the receipt of the recommendations and their availability for inspection and copying. On or about February 25, 1972, the Advisory Committee on Asbestos Dust submitted its written recommendations to the Assistant Secretary of Labor for Occupational Safety and Health. Pursuant to the notice of rule making, a hearing was held on March 14 through 17,1972, for the purpose of receiving oral data, views, and arguments concerning the proposed standard. On or about March 31,1972, the presiding hearing ex aminer certified to the Assistant Secre tary of Labor for Occupational Safety and Health the record of the proceeding. The record includes prehearing written comments, a transcript of the oral pres entations made at the hearing, and nu merous exhibits received during the course of the hearing or within the pe riod allowed after the close of the hearing. The proposed standard dealt with (1) permissible concentrations of asbestos fibers; (2) methods of compliance; (3) warning signs; (4) monitoring; (5) med ical examinations; and (6) recordkeep ing. Each of these major proposals elic ited comments, arguments, objections, and counterproposals. They all have been examined and considered. I. Acceptable concentrations of asbes tos dust. The proposed standard would limit occupational exposure to 8-hour time-weighted average (TWA) airborne concentrations of asbestos dust not ex ceeding five fibers longer than five micrometers per milliliter. Concentra tions above five fibers but not to exceed 10 fibers (ceiiing concentration) would be permitted up to 15 minutes in an hour, but for not more than 5 hours in any one 8-hour day. NIOSH in effect has recommended tlffit the five-fiber TWA and 10-fiber peak concentrations be permitted only for 2 years; thereafter. TWA concentra tions should be not more than 2 fibers per cubic centimeter (cm.3) of air, and peak concentrations should not exceed 10 fibers/cm.3, with no time restriction. Numerous objections and counterpro posals have been made, with regard to both the limits of asbestos fiber concen trations and the time periods to comply with them. Some, for example, have rec ommended return to a 12-fiber standard of an earlier day; i e., a level adopted under the Walsh-Healey Public Con tracts Act in 1969. Others have recom mended a two-fiber standard to become effective in 6 months, then a one-fiber standard for 2 years, and finally a zerofiber standard after 3 years. These rec ommendations give a fair indication of the wide spread of the counterproposals. No one has disputed that exposure to asbestos of high enough intensity and long enough duration is causally related to asbestosis and cancers. The dispute is as to the determination of a specific level below which exposure is safe. Various studies attempting to establish quantita tive relations between specific levels of exposure to asbestos fibers and the ap pearance of adverse biological manifes tations. such as asbestosis, lung cancers, and mesothelioma, have given rise to controversy as to the validity of the measuring teclmiques used and the relia bility of the relations attempted to be established. Because of the long lapse of time between onset of exposure and biological manifestations, we have now evidence of the consequences of exposure, but we do not have, in general, accurate measures of the levels of exposure oc curring 20 or 30 years ago, which have given rise to these consequences. There are also controversies concerning the relative toxicity of the various kinds of asbestos, and varying hazards in dif ferent workplaces. It is fair to say that the controversy has centered in the area between a two- fiber TWA concentration and five-fiber TWA concentration, with variations on the time needed for compliance. Many employers support a five-fiber TWA. Most medical opinion is divided between a two-fiber standard and a five-fiber standard. ' , In view of the undisputed grave con sequences from exposure to asbestos fibers, it is essential that the exposure be regulated now, on the basis of the best evidence available now, even though it may not be as good as scientifically de sirable. An asbestos standard can be re evaluated in the light of the results of ongoing studies, and future studies, but cannot wait for them. Lives of employees are at stake. It is concluded that there should be one minimum standard of exposure to asbestos applicable to all workplaces ex posed to any kind, or mixture of kinds, of asbestos. Reasons of practical ad ministration preclude a variety of stand ards for different kinds of asbestos and of workplaces. Also, while the evidence tends to show that crocidolite, for in stance, is more harmful than chrysolite, the evidence is not sufficient to establish separate standards for varieties of asbestos. Because there must be one standard governing exposure to ail varieties of asbestos, and in workplaces apparently' more hazardous than others; because some present employees with regular ex posure to asbestos have probably al ready accumulated great doses of asbes tos fibers, due to higher levels of ex posure in the past; because it appears that levels of exposure which may be safe with regard to asbestosis are r.ot safe with regard to mesothelioma: be cause the statute requires the protection of every employee, even of one who may have regular exposure to asbestos during a working life which may reach, or eten exceed, 40 years; and because of several other considerations which have been urged and are reflected in the record of the proceeding, the conflict in the medi cal evidence is resolved in favor of the health of employees. As of July 1, 1976, TWA concentrations of asbestos fibers longer than 5 micrometers will not be nliowed to exceed two fibers cc., with a ceiling value of 10 fibcrs/cc. The current TWA concentrations of five fibers, and FEDERAL REGISTER, VOl. 57, NO. 110--WEDNESDAY, JUNE 7, 1972 UCC 013130 A 4^ fO> yoj RULES AND REGULATIONS 11319 ceiling concentrations of 10 fibcrs/cc. fibers, so that these would r.ot be released 6. Records. The standard, as proposed will be permitted until July 1, 1976. dur in the normal use of the products, should and as adopted, requires maintenance of ing what will be a transitional period not be required to be lab-eleu, and (2) records of monitoring and of medical deemed necessary to r.'iow employers to words such as "dancer" and "cancer" are examinations. Most of the controversy m moke the needed changes for coming unwarranted!!' alarming. tills area has revolved around the ques into compliance with tiie more stringent Both contentions have merit, and the tion whether an employer should be al standard. . standard has been changed, accordingly. lowed to have access to the results of The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. The operations subject to the single asbestos would have required personal monitor apprehension of those who have argued standard (textile, manufacturing, indus ing and environmental monitoring. against employer access is based on the trial. and marine installation, etc.) will Many issues have been raised concerning expectation that some employers will use meet varying degrees of difficulty in the availability and reliability of meas the medical examinations as a means of complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and plants, extensive redesign and reloca toring. and conditions in which monitor worse, as grounds for discharging current tion of equipment may be needed. It ap ing should be required. The Rdopted employees, who show signs of being af pears. however, the deiay in the effective standard takes the objections into con fected by exposure to asbestos. Since the date of the two-fiber standard will pro sideration. It requires periodic monitor purpose of the medical examinations is vide all employers a reasonable time to ing at intervals no longer than 6 months, to monitor the health of employees ex comply. At the same time, so long as the thus allowing considerable time and dis posed to the hazards of abestos. em ceiling limit is complied with, no harm cretion, and prescribes the use of the ployees cannot in reason be granted the Is reasonably expected to result from ex membrane filter method, which is an ac privilege of refusing to disclose to their posures during the transitional period. ceptable method for determination of employers results of occupational expo 2. Methods of compliance. It has been asbestos fibers. sure. It does not make sense to require pointed out by many persons, that pro It has also been recommended that employers to provide medical examina tection against asbestos fibers is best employees or their representatives should tions if they cannot know and use the obtained by controlling the generation of have an opportunity to observe the results of the examinations. For these fibers first, and secondly, by controlling monitoring. The recommendation has reasons the standard provides that em the dispersion of released fibers Into the been accepted. ployers may have a. restricted access to ambient air of the workplaces. Therefore, 5. Medical examinations. The pro t arue medical information. the standard requires feasible techno logical controls and appropriate work practices ns the primary means of com pliance. Rotation of employees as a way of meeting the TWA concentration re quirement is allowed only in stated ex ceptional circumstances, because, as a general rule, it would be difficult to Im plement. Personal protective equipment, such as respirators, cannot be relied upon because, among other reasons, they may be so uncomfortable as to be bur densome, except for short periods of time. Therefore, it is expected that res pirators and shift relation will be used during the period necessary to install en gineering controls and to train employ ees in sound work practices, but, after technological compliance has been achieved, their use must be limited to special work situations and emergencies. Where both are practicable, shift rota tion is required. 3. Labeling. Tire proposed standard stopped short of requiring labeling as bestos and asbestos-containing products. The proposed standard would have re posed standard would only require an appropriate medical examination on a periodic basis. The generality of the pro posal has attracted many objections and also many helpful comments. The recom mendations of NIOSH and of the Advi sory Committee on Asbestos Dust were much more specific with respect to both frequency and type of medical examina tions to be required. The comments vary as to the class of employees to be ex amined and as to the frequency of the examinations. The adopted standard requires medical examinations both at the beginning and the termination of employments exposed to concentrations of asbestos fibers, and also requires annual medical examina tions of every employee exposed to air borne concentrations of asbestos. It has been pointed out that in certain indus tries. such as construction, an employee may work for several employers during the same year. Accordingly, the standard does not require either preemployment, or termination, or periodic examinaton of any employee who has been examined On the other hand, there is no Inten tion to allow employers to abuse medical information obtained pursuant to the Act, to the detriment of employees. Therefore, the administration of the medical records requirement will be closely watched, and, in cases of abuse, appropriate action will be considered. The issues discussed above are believed to be tlie major ones. Numerous other is sues have been raised in the rulemaking proceedings. Some have been referred to incidentally. Many recommendations, for instance, about work practices, arc so obviously' meritorious that their adop tion needs no exposition here. Other recommendations and many objections have not been adopted for a variety of reasons which should be manifest. Sev eral, for instance, have recommended the use of respirators only pursuant to a variance, or in cases of emergency and occasional short-term exposures. The recommendation with respect to vari ances undoubtedly has many merits, but is considered administratively im quired only warning signs at locations in accordance with the standard within practical. where asbestos hazards are present. the past year. Accordingly, after consideration of the However, labeling, rather than warning signs, has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Dust recom mended labels for asbestos products and One question which has been raised goes to whether the employer or the em ployee should be allowed to choose the examining physician. The standard gives the option to the employer. Since whole record of the proceeding, and pursuant to sections 6 (b) and (c) and 8(c) of the Wiillams-Steiger Occupa tional Safety and Health Act of 1970 (SI containers, and these recommendations some employers already have a medical Stat. 1593. 1596, 1599; 29 U.5.C. 655, became very controversial in the course examination program in operation, and, 657), 29 CFR 1910.4, and to Secretary of of the proceeding. Many counterpro proposals have been made as to the lan guage of the warning as well as to the products to be subject to the labeling requirements. Employers, ha general, also, have medical departments with some expertise in the diagnosis of abestos-related diseases. It seems more reasonable to permit them to utilize the present programs and expertise, than to Labor's Order No. 12-71 (36 F.R. 8754), Part 1910 of Title 29 of the Code of Fed eral Regulations is amended as set forth below. . strongly contend that (1) finished prod permit an employee to choose a private (1) Section 1910.93 is amended by re ucts which effectively entrap asbestos general practitioner. vising Table G-3 to read as follows; FH>EftAl JtEOISTER, VOL 37, NO. 110--WEDNESDAY, JUNE 7. 1972 UCC 013131 4 ^npu 11320 RULES AND REGULATIONS 1910.93 Air contaminants. to v-'hlch any employee may be exposed (d) Personal protective equipment-- * shall not exceed two fibers, long-?,- than (1) Comp'lance with the exposure limits Ta&me 0-3--Mtytwua ru^ 5 micrometers, per cubic centimeter of prescribed by paragraph <b) cf this sec air, os determined by the method pre tion may not be achieved by the use of Substance Mppcf Vlgfhi* scribed In paragraph in) of this section. respirators or shift rotation of em (3)Ceiling concentration. No em ployees. except: SilCicrQay:ustaarltlzin(er:espirable)...%.....j 250f ployee shall be exposed at any time to (1) During the time period necessary airborne cencemnUions of asbestos fibers in excess of 10 fibers, longer titan to install the engineering controls and to institute the work practices required ScBlO;f5 Quartz (total duM).................................... Critrbal1te: Vse >< the value calculated from the count or moss formulae for quartz. , TrMyn.itc: V.e y: the value calculated from the for mulae for quartz. Amorphous. fnc'udir.g natural dutomaceous earth................... ' 20 T-fl!Oi-i-2 SOmg/M* %S102+2 ` SOmg/M* rosio* 5 micrometers, per cubic centimeter of air, as determined by the method pre scribed in paragraph (e) c-f this section. (c) Methods of compliance--(1) En gineering methods, (it Engineering con trols. Engineering controls, such as, but not limited to, isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. by paragraph (c) of this section; (ii) In work situations in which the methods prescribed in paragraph (c) of this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of this section: or (iii) In emergencies. Silicate? (Irs than \% crys* tallitic silica): Mura......................................... Pcapstone...................... . Portland cement................. Graphite (natural)................... Coat dust (respirable fraction 20 20 so 16 (ID Local exhaust vcritilation. (a) Local exhaust ventilation and dust col lection systems shall be designed, con structed, Installed, avid maintained in accordance with the American National Standard Fundamentals Governing the (iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (i), (ii), or (iii) of this subpara graph, and both are practicable, person nel rotation shall be preferred and used. (2) Where a respirator is permitted by Itos than 6% SlOj)............................. ........ For more then Sit>2.................... .. 2.4mg/Mi or lOmg/M* Design and Operation of Local Exhaust Systems, ANSI ZD.2-1971. which Is in subparagraph (1) of this paragraph, it shall be selected from among those ap Inert or Nuisance Dust: Kespirable fraction............. . Total dust............................... %S!Oj+2 15 60 ISmy/M* Note: Conversion factors-- mi.p\.'fX35.3=millto particles per cubic meter *-particle prrc.c. f Millions of particles per cubic foot of air. based on impinger samples counted by light-field technics. * The percentage of crystalline silica In the formula Is the amount determined from a'r-barne samples, except in those Instances in wldch other methods have been shown to be epplic.tble As determined by the membrane filter method at 43 X phase contrast magnification. * T.tdh concentration and percent quartz for the application of this limit are to bo determined from the fraction passing a size-seiictor with the following characteristics: A* ro.tvnaniir diameter (unit density sphere) 2 2.5 35 6. U 10 Torrent passing selector 90 76 60 25 0 The measurements under this note refer to the use of sn AKl' Instrument. If the respirable fraction of coal du>: i? determined with a MKK the figure curespondlng to that o!2.4 Ms/MHu the table for coal dust is 4.5 Mg/M*. 2. A new S 1910.93a Is added to Part corporated by reference herein. <b) See 51910.6 concerning the avail ability of ANSI Z5.2-1971, and the maintenance of a historic file in connec tion therewith. The address of the Amer ican National Standards Institute is given in 1910.ICO. ` (iil) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits pre scribed in paragraph (b) of this section, such as, but not limited to. saws, scorers, ' abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems in accordance with subdivision <ii> of this subparagraph. (2) Wor/': practices--(i) Wet methods. Insofar as practicable, asbestos shali be handled, mixed, applied, removed, cut, scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the ex posure limits prescribed in paragraph <b) of this section, un!cS3 the usefulness of the product would be diminished thereby. <ii) Particular products and opera proved by the Bureau of Mines. Depart ment of the Interior, or the National In stitute for Occupational Safety and Health, Department of Health, Educa tion, and Welfare. und"r the provisions of 30 CFR Part 11 (37 F.R. 6214, Mar. 25, 1972), end shall be used in accordance with subdivisions (i), (ii), (iii), and (iv) of this subparagraph. (i) Air purifying respirators. A reusa ble or single use air purifying respirator, or a respirator described in subdivision (ii)or (iii) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure bruits prescribed in paragraph (b) of this section, when the . ceiling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonablv exnected to exceed no more than 10 times those limits. (ii) Powered air purifying respirators. A full facepiece powered air puriiying respirator, or a powered air purifying respirator, or a respirator described in subdivision (iii) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the respirator below the exposure limits pre 1910, reading as follows: 1910.93a Adiestos. tions. No asbestos cement, mortar, coat ing, grout, plaster, or similar material scribed in paragraph Co) of this section, when the ceiling or the 8-hcur time- containing asbestos shall be removed weighted average concentrations of (a) Definitions. For the purpose of from bags, cartons, or other containers asbestos fibers are reasonably expected this section, (1) "Asbestos" includes in which they are shipped, without being to exceed 10 times, but not 100 times, chrysotile, amesite, crocidolite, trtmo- either wetted, or enclosed, or ventilated those limits. lite, anthopbyliite, and actinolite. (2) "Asbestos fibers'' means asbestos fibers longer than 5 micrometers. <b) Permissible exposure to airborne so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed In paragraph (b) of this section. (iii) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand, supplied-air respirator concentrations of asbestos fibers--(1) (iil) Spraying, demolition, or removal. shall be used to reduce the concentra Standard effective July 7, 1972. The Employees engaged in the spraying of tions of airborne asbestos fibers in the 8-hour time-weighted average airborne asbestos, the removal, or demolition of respirator below the exposure limits pre concentrations of asbestos fibers to pipes, structures, or equipment covered scribed in paragraph (b) of tins section, which any employee may be exposed or insulated with asbestos, and in the when the ceiling or the 8-hour time- shall not exceed five fibers, longer than removal or demolition of asbestos in weighted average airborne concentra 5 micrometers, per cubic centimeter of sulation or -coverings shall be provided tions of asbestos fibers are reasonably air, as determined by the method pre scribed in paragraph <e) of this section. (2) Standard effective July 1. 1976. with respiratory equipment in accord ance with paragraph (d)(2) (iii) c: this section and with special clothing in ac expected to exceed 100 times those limits. (iv) Establishment of a respirator pro The 8-hour time-weighted average air cordance with paragraph (d> C3) of this gram. (a) The employer shall establish borne concentrations of asbestos fibers section. a respirator program in accordance with FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1972 UCC 013132 RULES AND REGULATIONS 11321 the requirement.- of the American Na where asbestos fibers are released to be subparagraph shall conform to the re tional Standard* Practices for Respira monitored in such a way as to determine quirements of 20" x 14" vertical format tory Protection. ANSI Z83.2-19G9. v.'tdch whether every employee's exposure to signs specified in 5 1910.145(d i4>. and is incorporated by reference herein. asbestos fiLc-rs is below the limits pre to this subdivision. The sigr.a shall dis b. See S.191P.fi concerning tlas avail scribed in paragraph (b) of this sec play the following legend in the lower ability of ANSI 2.S3.2-1369 and the main tion. If the limits are exceeded, the em panel, with letter sizes and styles of a tenance of an historic file in connection ployer shall immediately undertake a visibility at least equal to that specified therewith. The address of the American compliance program in accordance with in this subdivision. National Standards Institute is given in paragraph (c) of this section. 5 1910.100. (2) Personal monitoring--ii) Sam <c> No employee shall be assigned to ples shall be collected from within the tasks requiring the use of respirators if, breathing zone of the employees, on Legend Asbestos______________ Notation 1" Sana Serif, Gothic or Block. based upon his most recent examination, membrane filters of 0.3 micrometer po- Dust Hazard an examining physician determines that rossity mounted in an open-face filter 'i" Sar.s Serif. Gothic or the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be impaired by his- use of a respirator. Such employee shall be rotated to another job or given the holder. Samples shall be taken for the determination of the 8-hour timeweighted average airborne concentra tions and of the ceiling concentrations of asbestos fibers. (ii) Sampling frequency and patterns. Avoid Breathing Dust___ Wear Assigned Protective Equipment. Do Not Remain In Area Unless Your Work Re quires It. Block. Gothic. >i" Gothic. U" Gothic. opportunity to transfer to a different po After the initial determinations required Breathing Asbestos Dust 14 point Gothic. sition whose duties he is able to perform by subparagraph (1) of this paragraph, May Be Hazardous To with the same employer, in the same geo sampies shall be of such frequency and Your Health. graphical area and with the same senior ity. status, anil rate of pay he had just prior to such transfer, if such a different position is available. 13) Special clothing: The employer shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. ' (4) Change rooms: (i) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed in paragraph (b> of this section, the em ployer shah provide change rooms for employees working regularly at the place. ui> Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. (iii) Laundering: (a) Laundering of pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b) of this section. (3) Environmental monitoring--(i) samples shall be collected fiom areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8- hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers. (ii) Sampling frequency end patterns. After the initial determinations required by subparagraph (I) of this paragraph, sampies shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the Spacing between lines shall be at least equal to the height of the upper of any two lines. (2) Caution labels--(:> Labeling. Cau tion labels shall be affixed to all raw materials, mixtures, scrap, waste, cebris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bending agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentra tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b> of this section will be released. 'ii) Label specifications. The caution labels required by subdivision (i) of this subparagraph shall be printed in letters of sufficient size and contrast as to be readily visible and legible. The label shall state: Caution Contains Asbestos Fibers Avoid Creating Dust ' asbestos contaminated clothing shall be employees. In no case shall sampling be done so as to prevent the release of air at intervals greater than 6 months for Breathing Asbestos Dust May Cause Serious Bodily Harm borne asbestos fibers in excess of the ex posure limits prescribed in paragraph tb) of this section. (b) Any employer who gives asbestoscontaminated clothing to another person for laundering shall inform such person of the requirement In (a) of this subdi vision to effectively prevent the release of airborne asbestos fibers in excess of the exposure limits prescribed in para graph (b) of this section. (c> Contaminated clothing shall be transported in sealed impermeable bags, or other closed, impermeable containers, and labeled In accordance with para graph (g) of this section. (e> Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by the employees whose exi>osures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (4) Employee observation of monitor ing. Affected employees- or their rep resentatives. shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and labels. (1) Cau tion signs, (i) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers-may be in excess of the exposure limits prescribed in paragraph (b) of this section. Signs shall be posted at such a distance from such a location so that an employee may read the signs (h) Housekeeping--(1) Cleaning. All external surfaces in any place of employ ment shall be maintained free of accu mulations of asbestos fibers if. with their dispersion, there would be an excessive concentration. (2) Waste disposal. Asbestos waste, scrap, debris, bags, containers, equip- ' ment, and asbestos-contaminated cloth? ing. consigned for disposal, which may produce in any reasonably foreseeable use. handling, storage, processing, dis posal. or transportation airborne concen trations of asbestos fibers in excess of the exposure limits prescribed in'- paragraph (b> of this section shall be collected and disposed of in sealed impermeable bags, or other closed, impermeable containers. (i> Recordkeeping--(1) Exposure rec membrane filter method at-400-450 X (magnification) (4 millimeter objective) with phase contrast illumination. (f) Monitoring--(1) Initial determi nations. Within 6 months of the publi cation of this section, every employer and take necessary protective steps be fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of airborne asbestos fibers. (il) Sign specifications. The warning ords. Every employer shall maintain rec ords of any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at least 3 years and shall be made avail able upon request to the Assistant Secre tary of Labor for Occupational Safety shall cause every place of employment signs required by subdivision (i) of this and Health, the Director of tiie National FEDERAL REGISTER, VOL. 37, NO. 110--WEDNESDAY, JUNE 7, 1972 A; UCC 013133 11322 RULES AND REGULATIONS Institute for Occupational Safety and Health, and to authorized representa tives of either. 12) Employee ccccss. Every employee and former employee shall have reason able access to any record required to be maintained by subparagraph (1) of this paragraph, which indicates the em ployee's own exposure to asbestos fibers. (3 Employee notification. Any em ployee found to have been exposed at any ' time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed in paragraph <b> of this section shall be notified in writing of the expo sure as soon as practicable but not later than 5 days of the finding. The employee shall also be timely notified of the cor rective action being taker.. <j) Medical examinations--O) Gen eral. The employer shall provide or make available at his cost, niedical examina tions relative to exposure to asbestos re quired by this paragraph. (2) Preplacement. Tne employer shall provide or make available to each of his employees, within 30 calendar days fol lowing his first, employment in an occupation exposed to rirbnrne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram (posterior-anterior 14 x 17 inches), a history to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEW.). (3) Annual examinations. On or be fore January 31. 1973. and at least an nually thereafter, every employer shall provide, or make available, comprehen sive medical examinations to each of his employees engaged in occupations ex posed to airborne concentrations of as bestos fibers. Such annual examination shall include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches), a liistory to elicit symptom atology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (FEW.). (4) Termination of employment. The employer shall provide, or make avail able, within 30 calendar days before or after the termination of employment of any employee engaged in an occupation exposed-to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall include, as a minimum, a chest roentgenogram (pos terior-anterior 14 x 17 inches) , a liistory to elicit symptomatology of respiratory disease, and pulmonary function tests to include forced vital capacity (FVC) and forced expiratory volume at 1 second (HEW.). (5> Recent examinations. No niedical examination is required of any em ployee. if adequate records show that the employee has been examined in ac cordance with tir.s paragraph within the past 1-year period. (6) Medical records--(i) Mainte nance. Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurate records of all such medical examina tions. Records shall be retained by employers for at least 20 years. (ii) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made available, for inspection and copying, to tile Assistant Secretary of Labor for Occupational Safety and Health, the Director of NIOSH. to authorized physi cians and medical consultants of either of them, and, upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the infor mation specifically required by this paragraph, and any other medical in formation related to occupational ex posure to asbestos fibers. 3. A new 1910.19 is added to Subpart B of Part 1910, reading as follows: 1910.19 Asbestos lu>l. Section 1910.93a shall apply to the ex posure of every employee to asbestos dust in every employment and place of employment covered by 1910.12, 1910.13, 5 1910.14, 1910.15, or 1910.16, in lieu of any different standard on ex posure to asbestos dust which would otherwise be applicable by virtue of any of those sections. Effective date. Paragraph (b) (2) of ! 1910.93a shall become effective July 1, 1976. All other provisions of 1919.93a, 1910.93, and 1910.19 shall become effec tive July 7, 1972. The current emergency temporary standard remains in effect until July 7, 1972. (Secs. 6. 8. 84 Stat. 1593, 1598; 29 U.S.C. 655, 657; 29 CFR 1910.4; Secretary of Labor's Order No. 12-71, 36 F.R. 8754) Signed at Washington, D.C., this 2d day of June 1972. G. C. Guenther, Assistant Secretary of Labor. (FR Doc.72-8574 Filed 6-6-72; 8; 48 am) UCC 013134 Material Safety Data September 1, 1972 , UNION CARBIDE CORPORATION 4625 ROYAL AVENUE NIAGARA FALLS, NEW YORK 14302 TELEPHONE: (716) 285-3311 EXT. 6567 PRODUCT: Chrysotile Asbestos TRADE NAMES: "Calidria" Asbestos CHEMICAL FORMULA: Mg6(0H)8Si4010 BOILING POINT AND MELTING POINT: Not Pertinent SPECIFIC GRAVITY (H20=1): 2.45 VOLATILE CONTENT: Absorbed Water 1 -- 4% By Weight. Structural Water Approximately 13% by Weight. APPEARANCE: Pellets or Fine White Powder. No odor. Very Slight Solubility in Water. Material is not Combustible. No Fire or Explosion Hazard. INERT MATERIAL: No Decomposition or Polymerization Conditions. PERMISSIBLE EXPOSURE TO AIRBORNE CONCENTRATION: The current standard of the Occupational Safety and Health Act of 1970 contains the following exposure limits: "The 8-hour time-weighted average airborne concentration of asbestos fibers to which employees are exposed shall not exceed 5 fibers per milliliter greater than 5 microns in length, as determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contrast illumination. No employee shall be exposed at any time to airborne concentrations of asbestos fibers in excess of 10 fibers per milliliter, longer than 5 microns." (Federal Register -- Vol. 37, June 7,1972, page 11320). EFFECTS OF OVER EXPOSURE: Prolonged over exposure may result in lung damage. EMERGENCY AND FIRST AID PROCEDURES: Not applicable. Material has no acute toxicity. STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: Avoid inhalation of dust. Remove spilled material by vacuum cleaner or by water wash. WASTE DISPOSAL METHOD: . If reasonably foreseeable handling will not produce airborne concentrations in excess of exposure limits, no special procedures are required. When limits are likely to be exceeded, waste and scrap shall be collected and disposed of in impermeable sealed bags or other closed, impermeable containers, suitably labelled. Union Carbide Corporation assumes no responsibility and makes no warranty, expressed or implied, repre-^ sentation, promise, or statement as to completeness, accuracy, or currency of any data provided. 4 104 UCC 013135 CALIDRIA ASBESTOS - TYPICAL CHEMICAL ANALYSIS Component ' Weight % MgO Si 02 A1203 Fe Ca Co Cr Cu Ni Se . Loss on Ignition (C02 & H2O) 41.9 41.8 0.5 1.4 0.075 0.012 0.15 0.005 0.22 <0.001 13.5 CALIDRIA ASBESTOS - TYPICAL SPECTROGRAPHIC ANALYSIS Component Ag A1 As Au B . Ba Be Bi Ca Cb Cd Co Cr Cs Cu Fe Gd Ge Hf Hg In Ir K La Li Mg Mn Mo Na Detection Limit, Analysis, Wt. % Wt. % 0.001 0.003 0.01 0.002 0.006 0.003 0.001 0.005 0.002 0.006 0.01 0.01 0.003 N.A.H) 0.001 0.006 0.01 0.005 0.03 0.02 0.03 0.03 N. A. 0.01 0.1 0.001 0.003 0.003 0.03 . 0.0002-0.002 0.08-0.8,0, N.D.(2) N.D. N.D. N.D. N.D. N.D. 0.008-0.03 . N.D. N.D. 0.008-0.08 0.02-0.2 -- 0.004-0.04 0.8-8.0 N.D. N.D. N.D. N.D. N.D. N.D. -- N.D. N.D. Major 0.008-0.08 N.D. N.D. Detection Limit, Analysis, Component Wt. % Wt. % Ni Os P Pb Pd Pt Rb Re Rh Ra Sb Sc Se Si Sn Sr Ta Te Th , Ti T1 U V W Y Yb Zn Zr 0.003 0.03 0.08 0.003 0.005 0.005 N. A. 0.03 0.02 0.03 0.01 0.01 -- 0.001 0.002 0.01 0.01 0.05 0.03 0.003 0.2 0.1 0.003 0.01 0.01 0.01 0.02 0.006 0.08-0.8 N.D. N.D. N.D. N.D. N.D. -- N.D. N.D. N.D. N.D. N.D. . <o.ooi(3; Major N.D. N.D. N.D. N.D. N.D. 0.004-0.04 N.D. N.D. N.D. N.D. N.D. N.D. N.D. N.D. ^N.A. - Not analyzed. ^N.D. - Not detected. chemical analysis. UCC 013136 4 4 Ob F.Thomas Anderson B55 NS TECHNICAL S-*V1C: O OiVILOPVEST IC'.V CH"M'.CA'_ L'.S A. LISOJ 713*23 J* 1672 rssics* o r^cr-'CTS di^a.^tmcnt Fr.zZ~?2*T. TEXAS 7734! OCLi Cr>-; ;!" Wow 5 t Ptw* *'ur* ii * U-- <' ::-:*.!/ r> ov_-cv;' -- * r -- r~ * \ ? *: 5 r ? : ~\ ? c ... \ r f V /7*. '" " V -.* v< ^ k *. k C'* * v* - w d 3w i*k BECAUSE THE DRY EXPANDED SAHAN M1C RGS?r! ERES, XD-7G5'i.CM, ARE VERY SMALL AND VERY LIGHT (cn .6 pcf DU Li'. DENSITY), THEY TEND TO DUST1 VERY EASILY AND EE HARD TO HANDLE. IT HAS BEEN FOUND THAT XD-7C51.04 CAN DH TRANSFERRED FROM THE PACXiNG CARTON TO A MIXING CONTAINER VERY READILY USING A VACUUM TRANSFER SYSTEM AS DESCRIBED RE LOW. FILTER STACK ASSAY. C ii ('" 1. i t CP !C oc L.-li i i C . 1 SEE TECHNICAL BULLETIN PAR AM MICROPFHERES-PAFETY AND HEALTH CONSIDERATIONS. ' 2pici: v:> APSE ORLY, DRUM OR MIX TARN, FILTER, 0 VACUUM UNIT SHOULD ALL BE CONNECTED V.'iTU METAL HOPE OR GROUNDING WIRE AND COMPLETE SYSTEM GROUNDED TO MINIMIZE STATIC ACCUMULATION. T* iiMni?;' .0 jvj v..n*v * * *r la. j f !.*.<. ?r , y.\** ..it'* 7r* CA .v C' *-- ;.il C ' " li* c , !R r-. I-.a* .*'*0 *'! THE DOW CHEMICAL COMPANY DESIGNED PRODUCTS Dr.PARTiV.EMT V.IDIAND. MICHIGAN '186-iQ 4 i ii UCC 013137 4 SARAN MICROSPHERES VACUUM TRANSFER SYSTEM Because the dry expanded saran microspheres, XD-7051.04, are very small and very light (ca. 6 pcf bulk density), they tend to dust1 very easily and be hard to handle. It has been found that XD-7051.04 can be transferred from the packing carton to a . Considerations. 2Pick up assembly, drum or mix tank> filter, & vacuum unit should all be connected with metal hose or grounding wire and complete system grounded to minimize static accumulation. Tnis information pro*vot^d in r;or>d b.it no w vrmty. express or imp? is o.iven ny is frc-'J-um t roni any p.itont owned tv "The D?v/ Oirm.caJ Company or by etli'jrs to t*? inferred. THE DOW CHEMICAL COMPANY DESIGNED PRODUCTS DEPARTMENT MIDLAND. MICHIGAN 48640 UCC 013138 4 4 - Q7 UCC 013139 ' J3ITST COLLECTION AS A PROFIT JISALTS HAZA3DS 35DBC23 DustuctorS* systems offer immediate, effective control over the hazardous and costly problems of dust created by portable renders, pneumatic chisels, wire brushes, senders and other tools -- even ultra high speed air driven tools used to v/ork heavy metals such as uranium. By the use of patented nozzles and hoods, fitted to individual tools, Dustuctor equipment traps breathing zone dust in the dangerous under 10 micron range at the source, and conveys it through small diameter tubing to a high efficiency separator. The small sized, lightweight extraction heads and integrated system design make Dustuctor highly flexible and maneuverable -- it becomes, essentially, a part of the tool itself. All this means decided advantages in terms of installation and operation costs. Unlike high-volume low vacuum systems. Dustuctor does not require massive ductwork or provisions for large amounts of make-up air. The system removes only the dust -- it does not draw out substantial volumes of conditioned air in the summer, or heated air in winter. The problem of negative pressure is eliminated. You don't need special grinding rooms. And reduced costs plus effective production means more profit. Dustuctor system performance is highly efficient. Silicosis, . asbestosis, and berylliosis threats are significantly reduced. Various other nuisance dusts which cause seemingly inert pneumoconioses are also brought largely under control with Dustuctor systems. A short technical description of Dustuctor is provided under the heading "Low Volume --High Velocity Exhaust Systems" in "Industrial Ventilation, A Manual cf Recommended Practice" published by the American Conference of Governmental Industriai Hygienists. Dustuctor offers the additional advantage of service as a heavy duty vacuum cleaning system. Shake-out sand spills, blasting grit or welding flux recovery, ore dust spillage from conveyors, batch conveying, and many other in-plant problems can be handled. These miscellaneous duties can usually be accomplished by a simple change of accessories on the piping system. Several hundred world wide installations have proven the effective ness of our Low Volume High Velocity dust control system. Let a Hoffman representative show you how you can reduce costs, cut down on operational hazards, end increase productivity, with the unique Dustuctor system. UCC 013140 li: i J, A S & R * BOEING * CANADA IRON FOUNDRIES CATERPILLAR DENVER POST CM GE B. F. GOODRICH HONEYWELL' KRC'GER CO. LEVER BRO. MARTIN CO. MERGENTHALER LINOTYPE PEERLESS POTTERY, INC. CHARLES PFIZER * RAYTHEON REMINGTON ARMS S.N.S.O. ROYAL ORDNANCE FACTORY STAUFFER UNION CARBIDE VICKERS-ARMSTRONG, LTD." WATERTOWN ARSENAL * WESTINGHOUSE MiTiSlAL CONTROLLaD/RSCOVESED aluminum chips aspirin dust beryllium dust BRASS CHIPS CARBON DUST etMENT CHIPS CERAMIC DUST CIRCUIT 30AR0 DUST COPPER CHIPS DETERGENT DUST EXPLOSIVES FI3ER GLASS DUST tSARHITE BEARING DUST OIL VAPOR PAPER DUST PHARMACEUTICAL TA3LETING DUST PLASTIC CHIPS PORCELAIN FRIT' SILICA DUST DRINK MIX TUNGSTEN CARBIDE DUST URANIUM CHIPS & DUST UCC 013141 -i=3r^SEPA3ATO& PICKUP POWER TO 12" HG Basic equipment for a typical vacuum cleaning system consists of a centrifugal exhauster connected to a separator. Smooth Flow tubing or steel pipe carries the dust/air mixture to the separator. The tubing extends throughout . the plant, with inlet valves at locations where collection is desired. A large selection of hose and tools is available to suit your application. Of proven cast-iron, four-bearing heavy-duty design, Hoffman exhausters permit continuous unattended operation at volumes up to 13,000 Cfm, JpTl vacuum to 12" hg. Dynamically balanced rotors provide for smooth running. 'L-v'V~.a-T / <r .V',. F3V-1 Standard motors and drive shafts are used. ~-J3rer p?-3 PERISTALTIC VALVE Patented Rubber diaphragm valve continuously discharges abrasive materials which would wreck a rotary feeder. a eft *$ EXHAUSTER n HINGE VALVE Unique valve for batch discharge. Flap is a cast iron spherical section with linkage arranged to be selfcompensating for wear. Seals against a rubber gasket placed out of the normal flow of material. Available in manually operated version, or air operated, as shown. m-ty'-Xr m'iv HEAVY-DUTY INDUSTRIAL SMOOTH-FLOW* Smooth-Flow pneumatic tubing and fittings have slip-fit joints ... no threads. They are easily installed by non-technical personnel, with every joint fastened airtight with an adhesive or tape on the bell and tube fitting. Hoffman Smooth-Flow piping assures you of full suction power from the vacuum machine to the point of work. PORTABLE VACUUM UNITS Hoffman heavy-duty portable vacuum cleaners through 15 HP. Mobility and flexibility enable the operator to do a thorough job of dust collecting or vacuum cleaning. Typical of the Hoffman portable units is the 10 HP HoffcoVac 100 developing 8.5" hg suction. Filtering area is 53 sq. ft. Removable dust bucket has a capacity of 7.5 cu. ft. ENGINEERING SERVICE Hoffman Application Engineers are located in every major city in the United States and, through subsidiary and affiliated companies, in Canada, Latin America and Europe. These men are specialists. They will focus Hoffman's 50 years of experience on your individual needs -- and can save you time and money. You will find their names in Thomas Register and the Yellow Pages of your phone directory, or you may contact us for the engineer serving you. There is no charge, no obligation, for their service. HOFFMAN ^pt DIVISION OF CLARKSON INDUSTRIES, INC. JSA/Air Appliance Department Hoffman Industries CANADA/Horfman Industries o? Canada Limited ENGLAND/Hoffman Air& Filtration Systems Ltd 103 Fourth. Avenue 5S Berta! Road. Toronto 15. Ontario Howard House -- Lloyd Street New Yo;k, New Yo'k 10003 TEL: 416-763-3523 Altrincham, Cheshire/TEL: 051-923-7402 ~EL: 212-577-3G03 OFFICES/PLANT3: UNITED STATES. CANADA, ENGLAND, GERMANY, FRANCE. SWITZERLAND, ITALY. .MEXICO A ; 4 1 ' 1UCC 013142 . Dusthofr systems and AMF Alcort i / turned a dirty job into a dean one. compatible with the pleasure craft A!sort manufactures. The use of disk sanders and belt senders in preparing fiberglass surfaces on Alcort's Sunfish, Sailf:sh. and Flyingfisfi lines was a rr.essy, dirty operation for the tool operators. Dust floating throughout the plant also created problems. Working with Hoffman engineers, ^.ccrt's manufacturing-engineer ing department installed two High Velocity DUSTHOFF Vacuum Sys tems with special intakes that fit right on the sanders. The final pick-up hoods in this case were manufactured by Alcort to meet their own special requirements. Re sult: Total control of respirable dust and highly effective control of large dust particles. The DUSTHOFF sys tems eliminated the problem of floating dust and made the senders' jobs a lot cleaner. . This is just one of the thousands of problems created by dust gen erating tools and machinery that High Velocity DUSTHOFF Vacuum Systems can solve. If you have a problem even remotely related, contact your nearest Hoffman Ap plication Engineer. Look him up in the yellow pages, or contact Hoff man directly. Hoffman Dust Control Systems,103 Fourth Ave., New York, New York 10003. HOFFiyLArai. __ OUST CONTROL SYSTEMS a ADivision of CLARKSON INDUSTRIES.INC.