Document 9KvEq2M5OKjbbG13wMJeVe03

National Place, Suite 911 1331 Pennsylvania Avenue, N.W. Washington, D.C. 20004 IS] Organization Resources IIISsl Counselors,Inc April 16, 1984 Hilton C. Lewinsohn, M.D, Assistant Corporate Medical Director Union Carbide Corporation Old Hidgebury Road Danbury, Connecticut 06817 Dear Hilton: Now that OSHA has published its NPR for Asbestos, we need to determine how we can best structure our response to support a PEL of 0.5 fibers per cubic centimeter of air. One important step that must be taken is to critically examine OSHA's Risk Estimate to identify those places where it is based on supposition and/or conditions that no longer exist. This will be a difficult effort, for the time available is short. According to the NPR, we must submit notices of intent to appear at the informal rulemaking hearing on or before May 10, 1984. Our comments must be submitted to OSHA by May 25, 1984, with the Hearing set for June 19, 1984. We will ask for an extension of the comment period of at least 30 days, but it appears unlikely that it will be granted. I am in the process of trying to get commitments of support for the funds necessary to hire a reputable scientist to analyze those elements of the OSHA risk estimate that over state the risk. If I can find enough support to raise 10,000 and do so quickly, we may be able to accomplish our goal. If I cannot find funds to support an outside effort, we must do what we can ourselves. Therefore, I would like to ask you to work closely with me as we attempt to develope a responsible and credible critique of OSHA's Asbestos Risk Assessment. I know that it will take a lot of work, and will impose an additional burden on on your already heavy schedule. Recognizing the above, I will be appreciative of any time you can spare to work with us on this important task. DKM;jkj fiIP I|y D 2 01984 UCC 005744