Document 9D6ar9m6N3nkDMLOLn875Xpp

FILE NAME Manhattan RBM DATE 1978 Aug 22 DOC RBM055 DOCUMENT DESCRIPTION MEMO The Most Important Points to be Included in an Industry Statement on Asbestos and Health Problems Raybestos fya aor] 7 Manhattan DIVISION and LOCATION TO Mr. John H. Marsh August 22 1978 SUBJECT Asbestos International Association The Most Import Points to be Included in an Statement on Asbestos and Health Problems Industry okc I have read Harry about my attitude Rhodes letter to you dated August 15 1978 and note his concern toward what triggers the medical surveillance of asbestos workers I have also Response to | read the sections in the OSHA dated April 9 1976 Excerpts from the Asbestos Industry It is not my intention to insist upon unnecessary medical examinations and I think that the insertion of the word occupationally in the 3rd line of item 6.3 on page 2 between employees and exposed will considerably narrow the field I am certain that the trigger for medical examinations should be occupational exposure and not exposure implied by limiting the surveillance to those persons regularly exposed to airborne asbestos fibers in excess of the prescribed standards The viewpoint expressed in the AIA document that it is unnecessary to keep under surveillance persons exposed to asbestos below the prescribed standard is not a valid one in the light of the acceptance by the industry that the exact level for the prevention of cancer has not been demonstrated It is essential to build up data on low levels of exposure and therefore all occupationally exposed workers should be examined regardless of fiber count At the same time effort should be made to insure that adequate records are made and kept every of exposure for showing the type of exposure duration of exposure and intensity each individual to correlate with subsequent medical parameters analyzed If the asbestos industry wanted to make a positive contribution the development of a viable technique for auditing the applicability of the provisions of the standard to various jobs and operations would be of immense value to workers industry and regulatory agencies alike Prives Hilton C. Lewinsohn | MEMO from the desk DR HILTON C. of LEWINSOHN CalidCris aCalliiddrriCaslsidris ABCESTOS UNION CARBIDE CORPORATION METALS DIVISION BOX NIAGARA FALLS N.Y. 14302 TEL 716-278-3376 August 15 1978 Mr. John Marsh Raybestos Corporate Headquarters 100 Oakview Drive Trumball CT 06611 Dear John I see only one serious difficulty with Hilton's comments on my 7/31/78 Draft attached i.e. with Item 6.3 In their response to the October 9 1975 OSHA Proposal the AIA took a strong position that there was a minimum exposure level below which medical examinations should not be required This position was based on the lack of medical usefulness of such examinations the inefficient use of limited medical resources that would be spent giving such examinations and the practical infeasibility of actually providing the number of examinations annually which would be required It is my understanding that this is also to be our position coming OSHA asbestos rulemaking An industry position that exposed to asbestos should be subject to routine periodic surveillance would seriously undercut this approach If we here let's discuss it as soon as possible in the forth- all employees medical have a problem _ Regards HBR rmm Attachment Harrison B. Rhodes Technology Manager HBR ASBESTOS INTERNATIONAL ASSOCIATION THE MOST IMPORTANT POINTS TO BE INCLUDED IN AN INDUSTRY STATEMENT ON ASBESTOS AND HEALTH PROBLEMS Asbestos like many other essential raw materials may be a danger to health if it is correctly used Cigarette smoking has a strong synergistic effect in increasing strong the of lung cancer health risk from exposure to asbestos believes weighted 3 Industry that a average exposure of 2 fibers fibers . industrial hygiene ofe an appropriate standard but recognizersecognizesthDaietlugtihcaelreeffiescts no conclusive evidence to either prove or disprove priateness of this level As a consequence of this uncertainty exposure should be controlled to the lowest practicable level between There is a long time interval wually exposure and appearance of disease and present cases are associated with levels of exposure in the which were cee ee past greatly in excess of those experienced in properly controlled modern operations 5. Industry recognizes the need to control worker exposure to asbestos and favors strict enforcInedumsterianltrupgrisouufsetessionals government authorities realistic regulations in cooperation ~ trades unions and in medical professors . and trade unions , with authorities is actions to ensure taking and safe 6. will continue to take all necessary pollution Industry of and healthy working conditions and the avoidance environmentealnvironmental The user of containing products is generally not at risk if there are no subsequent finishing operations which generate exposures above the limit pprecautirons ecautions There is the necesinstahre y no ardouse does documented 8 A Asbestos in 1 the noted in Item 2 If there are such finishing stipulated by the industry its publicpaufblicaf publicaf must be taken ambient air operations posis a risk to the community at large DRAFT DRAFT DRAFT DRAFT HBR seem DETAILED . ASBESTOS INTERNATIONAL ASSOCIATION STATEMENT OF THE INDUSTRY'S POSITION IN ASBESTOS AND HEALTH PROBLEMS RELATION TO 1. THE RISK TO HEALTH 1.1 Asbestos dust may represent a danger to health if it is inhaled . 2. ASBESTOSIS 2.1 If sufficient concentrations of fibrous dust are inhaled ever Many years prolonged fibrosis of the lung asbestosis may result later . Only Only one Cigarette Cigarette asbestosare more- chancnghoeansnges X smokers 3. susceptible LUNG 3.1 CANCER 90 who smoke twictweice seem more susceptible to lung - Asbestos workers who neither cancer than other people unless smoke nor work with asbestos The industry behews that advised advised to reduce 3.2 Asbestos workers advised not 20 smoke or their 3.2 smoking to a minimum because smoking particularly heavy smoking considerably increases the risk of developing lung cancer Dae ee 4. _ MESOTHELIOMA dose response 4.1 There appears to be a relationship between exposure to oo Not asbestos and the incidence of mesotheliobmuat all cases of mesothelioma can be associated with exposure to asbestos 4.2 While some medical authorities take a positive stand there is by no means general agreement about the alleged specific greater potcury we of crocidolite and amosite in the causation of this disease members The 4.3 majority of Association amphibole view that crocidolite ccanan regulations governanous precautions Asociation's Association's precautions set out inthe who currently use , take the used provided that the Asociation's publications are strictly observed. -2- 5 REGULATIONS AND THRESHOLD VALUES 5.1 The industry accepts the need for statutory regulations designed 5.2 5.3 airborne to ensure that asbestos is uo sedpsat felycontrol It is the industry's policy opt to exposure to manufacture asbestos fiber during to the lowest practicable level ~ but in any case not to exceed the 2 fibers limit In the absence of regulations in any country the Association recommends that the precautions out in its publication The Control of Asbestos Dust should be observed te 7 MANUFACTURE dust 6.1 Asbestos may be used in industry provided that the control measures recommended by the International Association are observed 6.2 It is the industry's policy that all of its employees should be fully informed of the level of risk to which they may be exposed 6.3 It is the industry's policy to ensure that areas where asbestos to in is used are monitored accordance with the regulatory requirements occupationally ofabtohvee csotunattryutoryand the country of use that all employees exposed to asbestos Shaorueldsubject to routine periodic medical surveillance | 7.1 If there are no subsequent finishing operations on products which release significant quantities of airborne fiber it is generally acknowledged that there are no health risks to the users of the products operations If finishing operations are undertaken baeplopwropriate precautions 7.2 Full information about possible hazards should be given to : products users of asbestos . = AL: USERS Continued 7.3 As yet labels there is no on asbestos uniform policy concerning products but many members the now use of warning believe that the industry should voluntarily label products where a possibility of significant user exposure exists -. MEASUREMENT OF AIRBORNE DUST 8.1 It is the industry's policy to take the lead in the development one and standardization of reliable techniques for this purpose ARC Jo that The industry recommends Finine 8.2 retained as the standard the membrane filter method be method of measurement of airborne asbestos concentrations until better alternatives have been tried proven Counting rriol . and correlated with it GENERAL PUBLIC considered by the indusly to be not 9.1 The general public is at risk from asbestos or asbestos -. 9.2 products Persons living near asbestos factories are not at risk provided International general the precautions issued by the Association are properly observeandd the emission of dust to the eveniment prevented oe . ee mete 10. RESEARCH 10.1 The industry supports research into medical and scientific questions associated with asbestos and asbestos disease - see ; 10.2 The industry encourages publication of the results of this research irrespective of whether these results are favorable to the industry or not