Document BvQE6J2BEQarBB5jYKr3KRv78

FILE NAME: Z< DATE: :ZZ>W DOC#: Z< DOCUMENT DESCRIPTION ZZZ/ZWZZZZZ ".~~.. " t .:",j ) " ~ /') '"j .( c -i "'" ,j, , ILLINOIS POLLUTION CONTROL BOARD January 6, 1971 I~ tne Matter of: ASBESTOS P~GULATIONS #R71-16 OPINION OF THE 30l\RD ON ADOPTION OF REGULATIONS (BY MR. LN,vTON): Proposed regulations relating to #24 asbestos dated June and 14, spray 1971. insulaHearings toinonth"eIseere re~)gUubllaitsihoends inweNreewhesllde.ttienr Granite City on October 6, 19, 1971. in Notice n October 15, and in Waukegan on October dr~ft, together wi~h the form of regulation Chicago o of the proposed =inal proposed for adoptlon, "JerF.' published on December 5, 1971 in Ne\vsited and a small nUiltber have letterec#e3i7v. edW . riht'etenadcoopmt mtehnets rewgeurelaitniovns today in the form as pubfying lan- been r lished in Ne'Nsletter #37, modified by some minor clari concern ln these regulations is ~o prevent guage. Our principal or linit the emissions into the atmosFhcetsre anredsuthletinrgesufrlotmingthedisuases- of asbestos and asbestos-bearing pathological consequences produ resulting =ram ingestion anc er the source ~rous ~ of this reineral. e This Opinion wlll co~sid uses of asbestos and asbestos bearing inhalatio and types products, of asoestos, the cause of ~h asbestos emissions and their demonstrated the :neasurement and moni tor- impact inq of upon the sbestos heal t:1 flbers of the communi ty, and the means available for emission abatemen~ rovisions a rol. The modlfieceantiotnhseimr aoderiginintahle psroupbosstaatlivaendpultimate and cont of the regulations, betw adoption, will likewise be discussed. The term "asbestos" is a naimrteugallvlyen intodeastvruarciteibtyleocf hDaraatucrtaelr. ochecumrraijnogr maslnbeedstoslslimcian~eersalos f aarevchrysotlle. crocidolite, amosite lite and actino- T and anthophyllitnee.ralsOf dliefsfseer r inimcphoertiarncmeetaarlelictreenleomental content, th, lite. These mi lber diameter, flexibility teasnd thhaartshdneteesrsm, inteentshileeirstirnednugs- range of E surface propertieS ann other attribu trlal uses and which, in gic reactivity. turn, Over affect 90% of their respinierdabainldityc,omrmeteerncitaiollny what is m to as "serpentine" sotile, sometimes referred and bl010 used as asbestos is chry asbestos. The remaining :ninerals are collectively referred ne-fcurth of the to as world hlboles. The United States uses about o t~is substance, most of which is imported from Canaaa amp production of anj Africa. (Ex. 3, ~ir Pollution Asnects of Asbestos, ber,1969, Litton Report .. Ex. 19, UA.irSb.ornDeepAarstbmeesntot so, f NHaEtiWon,SaelptAecmademy of Sciences, s1a9r7e1.'locAatsebdesptorsin- dceippaolsliyts inof VceorrD:Lolntet,rciCalalviafolureniain, AthreizoUnnaiteadndSNtoartet~ Carolina. No 3-437 "''''-!. } '""",1J(Pi," :::oJn.'1tercially fact which viable sources of asbestos are found in Illino~s, a might otherwise invoke a far more comprehensive set of regulations. The uniqueness and industrial usefulness of the mineral is a consequence of i~s flexibility, tensile inflammability and its resistance to acids, alkalies strength, 110nand electricity. Some asbestos fibers get into the atmosphere from non-ind~strial sources. See Asoestos Air Pollution Control, Institute for Environ- :nental -Quality, prepared by from rock outcrops, farming Colin F. Harwood, Ex. 20. These range and excavation for construction purposes to as t~e use of talcum powder. Emissions from rock, outcrops occur a consequence of natural eroding processes such as earthquakes, temperature, wind and rain. asbestos rock will likewise Farming of soils cause emission of in areas containing these fibers. Con- struction requiring excavation in asbestos containing rock for housi~g, pipe-laying anc road construction constitute ~ emission into the atmosphere. Recent research source of indicates ashes~os that tal cur.. powder, while basically a mineral rock dust, does contain fibrous material, and represents a threat of asbestos bodies. Obviously, control asbestos the thrus emissi~ns t f of rom t he reaulations these~sources. does not seek Further, the to absence of of asbestos danger. minino in It is-the Iplrloicneossis~ngeliomf inaasbteesstoths isin amcatnivufitay~tuarsinag soanudrce the use ~nd products to fabricati8n of asbestos and asbestos and fiber containins which t~e reg~latio~s are principally directed. ~hE health of the dangers inherent ~n asbestos processing asbestos inhalation arise at the start cycle and inclu~e the loadi~g and storage of milled asbestogs, otfhecotnrpaancstpedorftiinbgersof abndaggtheed masibxeinsgtos'of toasbtheestoospen- ing area, fluffin fibers with other mater~als. (Ex. 20, Hanvood, Page 7.) Principal user of all grades and varieties of asbes~os fibers is us e th d e to a sbestos convey -cemen water, t indust sewage, r y producing industrial asbestos-ce and gaseous ment prod pipe ucts and se as rving bestos as -ce c m ond ent uit in s d for ustry elect prod ric uct a s l i a n n c d lu tel de ephone roofing c able shin s. gl e s O~her , bui l d i n g boards, marlne these products board and laboratory bench tops. To manufacture willowed fibers are dry-~ixed with fine-ground silica, and a slurry formed by addition of industries require finishing steps water. The which again end prociucts of these generate asbestos emissions. These include saw~ng, turning, drilling and sanding, rge quant~ties of asbestos-laden dust, and some each producing la clinging to the surface of the items being worked upon, again becoming a potential emission source. A second major use of asbestos fibers is in the manufacture of asbestos vinyl floer t~le and asbestos asphalt road paving pounds. Here 'again, emiss~ons result from the manufact.ure of COD- ::hese products and to a lesser degree from the use and ultimate process~ns 3 - 438 ' and fabrication. ~roducts used for Asbestos roo=ing, papers represent a great variety of insulation, linings, heat and chemi~al ~esistant ~nsulation for pipes and automotive exhaust insulation. Pre-processing of asbestos fibers and the mixing of asbestos mpaapteer ciuntg~irnegdieanncts pcroocnesstsiitnugte reapn reemseinstssiona sfouurtrhcee.r 5A0~gracien, otfheasbuelsttio-s emissions into the atmosphere. Asbestos paint and ccating fillers utilize asbestos "shorts" breicloitvyereindcrfreoamsestheuthsmeeidldlien~nnsgtihtyeproospcr eraosyspianwqguheeonrepesetsrhaoetifiornpr,aeilntahtte.1vpeWothieennr~de ieaaslstbruefosctrtois- bearing paint is emissions is substant1al. Likewise, the wearing and aging of the paint becomes an additional source of emissions. Asbestos friction materials and gaskets represent a wide use of these minerals. Emissions result from triIT~ing of these products. Asbes~os the fabrication, molding is also used in the pro- and textile products. The term "roving" refers to t'cle finished duction of textile product, from which yarns are produced. Blended fibers are carded in senting a machines where the operation is essentially open, serious emission source due to the combing action preof the machine. Both the production of this product and its ultimate use presen t substantial sources of emissio:1. The spraying widest uses of the of asbestos for ins~lation constitutes product and, undoubtedly, one with the one ef the greates~ danger the potential, not only to the public at large. Prepared health of the workers involved but asbestos cement slurry 1S pumped ~o to the nozzle of a gun and sprayed directly to the surface, o~ alterna- t1vely a dry m~xture of mixed with water during asbestos cement is j:um?ed to the spraying operation. The the gun and material co~pris~n' the asbestos rock wool in insulation is formed by proportions of 30%, 15% co:nbining asbestos, cemen-c, and 55%, respectively. The and r:lineral r10st p:::-operties. commonly If calor used is alTl.Osite, possessing is required, crocidolite or superi.::>r thermal chrystotile fibers ~re- used. Among the un1que properties associated wi th asb'~stos cement insulation a:::-e low strength, together thermal cond~ctivity and inflammability and with good acoustic features, low cost, easy higb thick- ness control and application. Initial duct results from dry mixing of the cause of emissions 3Destos cement and from th~s mineral pro wool components. Care must also be exercised during L~e storage and transportation of the At the construction site, bag the mixture to prevent further emissions. bags are open and the dry material emptled into hoppers ",here further emissions ficant source of emissions, of course, is in occur. The most signithe spraying operation isttsrueclfti.onHsigithesduusttilcioznincegntarsabtieosntos s casnprabeyinsesenmeatnhdodms.easOuruerd reagt ucloanti-ons kimeeppoisneg anreqouuitrreimghent tbs anononaltlhisspraaycitnivgitoyf annodn-iamsbpoessetosstrf1inbgrEou'nst m hoautseer-ials. 3-439 " ......~ ,~ , '\ ,:i :} ",I;,... ,,;' 1,ddi1:~onal emission 0:: asbestos results from "Che "..lse of pre-fanned asbestos section's or blocks for insulation of pipes and boilers, and in the use of materials applied in a wet or slurry state. Asbestos cement products including roofing shingles, building boards and drain pipes have sealed surfaces and do not dust easily. HOi'7ever, emissions may result from their cutting or breaking. Other asbestos products used in construction and industry are asbestos paper, blankets, rope and sealing compounds. Emissions resulting from the use of these products depend on the type of material being fabricated, the amount and character of fabricat~on required, the location and nature of ~he site and the quantity of material being processed. Tightly bonded composites will have less potential for emissions than those loosely Dound. See R.ll6 and following testimony of Pundsack; Thompson, Ex. 5, Asbestos as an Urban Air Contaminant; Ex. 4, Selikoff, Asbestos, "Environment", March, 1969. Tvlentyseven industrial concerns in Illinois manufacture products using asbestos. Exhibit 20, Harwood, p. 56. Asbestos products are used in virtually all building construction and utility installation. A particularly obnoxious source of asbestos emission with extreme difficulty of control is the demolition of existing structures. Asbestos insulation and products present in demolished struc'tures generate substantial emissions into the atmosphere where control is difficult and the impact on persons in the vicinlty, both workers and res~dents, ~s extreme. For years, asbestos has been incorporated in building materials. In some forms of insulation and wallboard, the amount present is less than 20% of the total, but other materials consist principally or entirely of asbestos. When a building is demolished, areas of loosened asbestos are open to the ambient air and fibers are emitted. In general, single-family residential structures contain relatively small amounts of asbestos insulation. Demolition of industrial and co~ercial buildings that have been fireproofed with asbestos-contain~ng materials will prove to be an emission source in the future, requiring control measures. Asbestos is emitted into the atmosphere from brake linings and clutches. While these are unquestionably substantial sources of asbestos emissions in the ambient air, the character and potential of these sources have not been sufficiently documented to a point where we feel they can properly be the subject of regulatory action and control at the present time. Harwood, Ex. 20, p. 22 through 28. See Ex. 8 "Brake Lining Decomposition Products", Lynch, Journal of the Air Pollution Control Association, December 19, 1968. Having described the principal sources of asbestos emissions we next consider their pathological implications. The Litton Report states, Ex. 3, p. 40: 3 -440 :-")'- ,'" ;, ,.",,'" ~ ) Asbestos is an air pollutant which carries with it the 90tenti.aol r fomresnoatthieolri-oaml aoor fwothrledl.p<lliedue raepoi drempeicri- of lung ~oneum. cancer Asbestos bodies have been observed in random autopsies of one-fourth to one-nalf of the population of be Pittsb'Jroh, l'1iami and San Francisco and will probabl-, found in - ::he people of every large ci ty. '" the effects of the asbestos being inhaled today may not be reflected in the general health of the population until the 1990's or the next century." to p r Th ote e c t object those i ve wh o of b y t he regulation occu~ational s a must ctivi t b y e twoor ph fold, ysica l f irst, conti g u i t y , -2ither to the asbestos use i~s of this pollutant, or in the asbestos user become the other words, to protect those potential with both vict environmental orientation; and secondly, to provide occupational and :ueasures t.nat will protect the ambient air against an asbestos bui bey ld-u ond p th tha ose t will occup have ation adv ally erse or effect upon th environ~entally e g or eneral ientate p d ubl at i c th e source. As sLated by Tho:npson, (Ex. 5), Beca~se asbestos iosntvaiinrtiungallpyroidnudcetsstraurectiubseled ainnd toswo ns, ;nany of the the average asbestos c urban dweller lS theoretically exposed to the inhalation of asbestos fibers on a residential basis." After posed revie'tJing the incidence of death to asbestos dust, over a 20-year among asbestos workers, e;{period, Selikoff, Ex. 4, states: These expeerisetoncs esdinselgashel.ighIt t oinse pnoowrtiroecnogonf izthede cthuarrtent spectrum of asb direct occupational exposure to asbestos results in a hazard much morel ysieganrsif, ichaonwtevtehra, n afdodrimtieornlyal apprporbelceimastedh.ave:n the last severa been recognized which add another dimension: the possibility that the utiliezrahtaiposnoonef oasfbethsetoscomismuansistoy caiatteldargwei.th Ta hmisuch wider risk, p is less well defined, much less well documented, but beca'Jse of its potential importance, of considerable concern. It is in this context that our regulations must be structured. The onset of morbidity and lethal diseases have been attri- buted to asbestos inhalation calcification, lung cancer, and ingestion. and mesotheliomas Asbestosis, are known pleural to result from near exposure asbestos to asbestos. Surveys of mines and factorles have people living revealed that or working many nonoccupa- tfiroomnaal sbcaessetoss.oifn atshbeesptoosllius teadnd amiersootrhefrloimo~aashbaevsetosocccaurrrreieddehiothmee ron the clothing of workers. J - 441 The fate o~ the asbes~os ~i~er once it is ln~aled and deJ='osi::.ed in ::.J1e :~ung is still q:uestionab.Le. The short fibers, less t~a~ .5 m18rons in length, have i~ the pa5~ been ignored, probably because they e.re :11Lich t:oo narrow to be visible l.m:ier a llght PH cros~o?e. The ~onser fibers are encrustea in an iron-bearing protein rOr!:"! t<,!ymeo "asr."'stos bco.:es;' ",hieh 3.re more easily visib:"e. AmO~I::l' aSC8tos wor;,ers, eVlcence 01 p..lll'"!::Jn3r~' asbes"C.csi::;, also know~ as asbestot:ic ?neuAccc~iosis, an asbestos i~Guced 5C3rrln~ 8f "':he 2.u~:;s I :is CCTr..J:1. 'r:-,:",s c0cditi:>!1 !:"esults if: a ::iffuS8 fibrosis ,USU!}';'':''::' 2 r: t.h'2 1::,\lf2::: :ob::.:s uf CH? :L'.:nc. Pl!l~no~c..r~' asbestos1s has ;:,ee:-: c5.11e~ a :n::mc:sYDp'.:::Jr:l3.tic disease, charact:2r::..z=c by pa~nful breathicg and 1unS di~order. See Nicnclson s~atement, Ex. 21, R.35 and followlnq. Li~ton Ex. 3, p. 4 and following. Asbest~sis Jsuaily devslops after lo~~ expusur~ ~o h~gh co~cen~ratluns of asbe8t02 Just. the risk v&ryin~ d1re~tly with ~ne er le~gth o~ exposere and the dcst concentr~tion. FcllDwlng ccn~inued exposu~e to ~igh concentrations ~uSt, asoestosis way ~evelo~ ~uily in 7 ~o 9 years and ~ay cause deat~ as early 2S 13 years after the onse~ of: exposure.. The conmCi! exp:::lsure pe:Cloc beIrrE! recosrnl- ~ion of asoestoslS as observecL a:nor..g asbestos workers is 20 t.o 40 years, '"ith deat11 0110\-1ing about 2 to 10 year", ':"2.ter. 01:ce establisned, asbestosis progresses eve~ after the exposure to dust ceases: illness or death Cdn cccu= lon~ after exposure to concen- trations no"C producing i:n.11~elllClte effects. The prolonged latency period between exposure and thE first sig~s of asbestosis ~akes i t d~fflc~lt t~ establish dose-ti~e re~a r:ionsnipE, In 1946, 700 cases of asbestos.1.S were fou!1d in Germany a.'11ong Cl total of approximately 8,000 employees in the asbestos lndust~v 125 cases of asbestosis of the lung in X-ray examinations of 476 asbestos workers were foend 1n one co~pany in ~inland. The occurrenc of asbestosis in members of thlS worker group appears to rise with the duration of the employment: A morbidity of 80 percent among Ens 11sh asbes tos ,..;orkers wi th over 20 years of employment :las been reported. Selikoff and others investigated 1,522 asbestos ins~la~ion wcrkers in the New York-New Jersey ~etropolitan area. A.mon,; 392 individuJ.ls eXaJ'1ined more than 20 years from the onset of exposure, X-Rav evidence of asbestosis was found in 339. In halE of these, the ~sbestosis was moderate or extensive. In individuals with less than 20 years of exposure, radiological evidence of asjestosis was less frequent and when present, less likely to be extenslVE. 3 - 442 711e wost cor,nor. cor,lplicatio:1 of asbestosis is car-cee:- of the J l~n;. ,]m"ever, canee:;: 2: t~e lung appare:1tly induced by asbestos ~ar a?pe3~ u~ac::;onDanied by asbestosis. The associatIon of lung cancer ~ith ex?osure to asbestos dust ~as ~een tne subject of ~any ~nvestigations 1n recent years and ,):-:-:'0nsi'''el1' docu~el1te::: in t!":e ljter~t'.lre. See E:-:. 3, Litton; ;::;.:. 19 Nat I::' Acue.. an,j a rnrre1<ltir,n Detween asbestosis 3nu :ung cancer a?~ears def1nite. Tt IS recognIzed t~at cancer of thG lung produced by usbestos ~eeds f~rther study. Th~ la~e:1t period between exposure and evidence of carCLno~~ ~aj be e~en lorger than for asbestosis. Little is known ;:;.bcu:' ~_:le dose-':.i::;e ::::-elationship. Cases 0: l\.:ng cancer have beer, 8bservcJ w~~n only a very short exposur2 or no exposure ~o asbestos '-""as knO\'Jl:. Fur~her::lOre, the low nu:nber 8 11 asbestos booies 11 obser'lcci 1.1: o:1(?-four-:'h co one-half of che urban population may be 3uffi2iEnt to ~ause cancer. BeCHuse the lcng lIa5bestos bodies" re~,ain in t:1e Iu;):::s, a person ;..,rho has i:1haled asbestos may carry the ~ote:1tl~l :or the reSL of h1S life to develop carC1Doma of tie lunq. i!orcovE' t', : t has not been deter:nined whether more than one fiber _5 ~0ccss~ry to ind~ce a ~a1ignant tumor. I t ~as bee~ suggested that ::'C: ;'r:)l;2Di L,::y .)f cancer inducticn is Froporticnal to the number of dsbesto3 ::..L'.:rs, :lll!.'.:JCL Qc:. s'.J5ce?tible cells, the cO:1centration of =Qr2i~og2ns ~n :h8 fibers, and the ti~e from exposure. ~hy asbes~cs is carc~nogenic is ~ot clearly understood. A~ least three hypctheses have been advanced: 1. T~at the fibers act as a physical lrritant which after 20 to 30 years of constant irritation induces a tUTI',O"!:". 2. That ~he fibcrs contain small Cli"TlOunts of carcinogens, such as benzo(a)lJyrene, nickel, and chromium which are eluted fro~ the fibers by the serum in the lungs. 3, Tha~ the flbers accu~ulate In the lung and are immobilized as "asbestos bodies ll which disintegrate after 20 to 40 years. The resultinq free ?articles cause asbestosis Qr carcino~a of the lu~g. P:Cl'iary turnors of t;1e ?1eura and per:' toncum are so rare that ~or years they were considered to be pathologic curiosities. In 1960 the fIrst large series of cases of diffuse ~esothelioma were reported, in South Africa. In trying to ex?lain this mysterious e:::idemic, lIasbestos bodies ll ""'cre four..d in t::-te lungs of some of t~ese oatients. An association with exposure to the Cace of Good '101'8 a~bestos fields, or the industrial 'else of asbestos ~ was establl~hed in 32 ~f 33 ?atients wlth h1stoloS~c311y proved pleural ~eso "C':,e::'i(;:-:2, Tbe :l3]ori ty of t:1ese patlents had :-lot actually '"lOr'-;ed w:~h 3shes~os bu~ had lived in the vici::ity of t~e ~lnes and mills, ~ -- .14 J and so~e ~ad left ~hese areas of exposure as young children. The average period bet,veen exposure and developmem:. of the tumor ',vas 20 t.o 40 years. Later studies verified this interrelat.ionship between asbestos exposure and ~e50thelioma. See Litton Report, Ex. 19, p. 12; Nicholson, Ex. 21; Selikoff, Ex. 4. In an atteTI'.p1: to determine \,,~ether r.esothelioma c:: the serosal surfaces was relateci in any way to asbes~c5 ~~~osure in the Gnlted States, Sellkoff studied 307 consecutive deaths among asbestos irselation workers in the ~ortheas~ern Uni~ed S1:ates. Thev found 10 deat.hs caused by four pleural and six peritoneal m0s~~~elIo~as. In addition, these workers had a high death rate a~cributed to cancer of the 5tonac~, colon, and rect.um. Of the 307 deatjs, 40.4 percent were attributed to cancer, 5.5 percent to asbestosis, and 54.1 perc:e!l.t to ether causes. In a second study, the irvestigators rc2Viewed 26 consecutive autopsies of pa~ients with asbestosis, and found four ~esotheliomas of the pleura and three oE ~je peritoncun. Mesothelioma is now considered a freauent ca~se of death amona asbestos workers. Nu attempt has bee:1 made ':'0 surn:marize the rcport~ of ~esothelioma, since they appear al~ost weekly in the current li~er ature. Se far, however, there appear to be few cases anong the ge:1~r al population. Selikoff reviewed 31,652 deaths am on? the general population of over 1,048,183 in the United Stat.es and found only three cases of mesothellona. ~oreover, he points out that asbestos is not t.he only cause of mEsothelioma; it has also been prod~ced by silica and polyurethane. W~i12 the exact cause ef lung cancer or pleural periotoneal nesothelio~i;a induced by asb2stGs is ncn: kno\..rn, air pollution by other pollutants ~ay accelerate the morbidity. One form of air poll~tion which is easily studIed in individuals is smokinG. Se1ikoff recently studied the mort~lity of 370 asbestos insula~lon workers. In this group, 24 ~en died of lung cancer and all had a history of smoking. See liieiss, LX. 15, "Cigarette Smoking, Asbestos, and Pulmonary Fibrosis", Anerican Review of Resplratory Disease. Vol. 104, 1971. This rate was elght ti~es greater than the expected mortality rate, with age and smokIng ~aDits taken into account. The recent finding of "asbestos bodies" in one-four-::h to cn:?half of the ~rban populatlon has added new i~?etus to the examination of asbestos as a general air pollutant. An "asbestos body" has been defined as "an elongated golden or reddish-brown structure usually with clubbed ends. The shaft, which often shows a segmented or beaded a?~earance, is usually straight, but sometimes curvilinear WIth a tendency toward symmetry. usually it is froCTl 3 to 5 mlCTons i:1 dianet8r anc} 20 ~_c 100 ~icrcns in length. The coating contains iron deffionstrable by 3 -444 Perle's stain (Prussian blue reaction), and probably composed of fe"riti" or ferrlt~n-llke material. I t ~ay cover the structure co~ple~ely, ~asking the c~ntral fiber from direct view, or ~ay be incom~le~e in the central Dcrtion of the shaft or in the interstices of t~~ body, =evenlinq an ~~panse of naked fiber. Thc!:"e l5 no doubt tnai: t;"e "asbestos bodies" formed :"n Loe lL!E;s of t!lC: asbes"C.:ls "",ol.-kers contain asbestos ( and it 1.S probable that serne a=e contalned in tnose found in the lungs of the general iJ0::-,U:" a ti ~):"'._ Evidence that persons other Lhan those working directly with asbestos ~inerals are belng exposed to asbestos is of several ty~es. Asbestos fibers can be dem:lns~raLed in the lungs of persons no~ :lccu~~tionally ex?osed. In a ew geographl.c areas, patho16gic c~dnges regarded as representing a reaction to asbestos such as ;-::'curaJ. ci'.l:ci::::i.cation hav~ been :ound in po?ulations with :10 history of :lcGupational ex?os~re. Asbes~os fibers have been demonstrated in ambient air. Str~c=u:ces th.::lt appear ::0 be fi-bers coated with a pigrnented material ~ere described i~ lung tissue as early as 1907. These struc-cures vvere ac::ually fibers c ca ted wi th hemosiderin. Because ~Iose who work with asbestos exhibit them a few months after starting work, It was recognized that they were evidence of ex?osure, but J not of asbestcsis. tlesl':jna::io!l . The teG1 "asbestos body" caf.1e to be the preferred As lo~S as the coated flbers were found h~ve been occ~paticnally exposed to asbestos, central fiber -,-:as selcion: questioned, a:"though sinilar obJects were found in persons wit~ no aSbestos. in persons known to the Identi::y of the from time to tiDe known exposure to ldentif~ca-cion of the core fibers nas proved to be a formldable technical tasK. \'ilthout f:ber-')y-fiber 3.na:'..:sis, a:Cl -:[>2-;:- can be 5Ji~ is th2~ co~te~ fib2rs rcse~bling those in asbestos workers are ?rcscnt i:-1 :_1Dst ?9rSOnS in our urban centers. Stripping the coa-:::ing a~d ana:'..yz:ng the cores by varlOUS techniques can sometimes demonstr3tc ~~at the cores are asbestos, but the process lS tedlous and o.':t'-'n in20:1clusi'fe. rl more appropriate ter::l is "ferrugineous body". l>tt2nt~.::n: is ,,0'11 bein0 d_"i.rected tm'lara study, !lot of the ferruglnous b~iJCS al')ne, but of the total fiber content of the lungs, whether sU2h ~ibers are coated er uncoated. E'1::.:l2nCe is strong that :c\ost human lunqs harbor thou::. ands or ~L:!icns of fibers. ~ome of these are chrysotile asbestos, and other ty~2S of asb2stos ~:nera::'s are probably there. In most persons not :ccu-~ation:-l!l,' e:':j:oseG to asbestos, the nuiTlbers of flbers are relati'J~:~- s~-_all, - CO"~-JCl:::-ed v7ith the n'.lT1bers fDund in -the occnp2.tionally (?:'::~Js2d. Th2 E~~'s~<:;~ati,-- a:.Jp.J_ica::io;l of quantltative techn2C?ues 3 -445 ~easuring both coated and u~coated fibers, is n2ed2~ to ~e~ine a g~adi8~t ~f accum~lated fibers for correlatio~ with i~cidenc~ o~ cise2.se I on tt,e one ~and, and iistory of environmental e::':)os:n;o. r;:! ::.he othc r. A:though there appears no doub~ that asbestos cibers ara ~~~ sent in ~any human lungs, ~here are sources of airborne fibers :J':.:1er '.:~:1.D iJ.sbes"Cos, Some are probably C:cr-i'ved fro:.) the bun-nO': o E leaves ant:" ?lant ?roducts, SUC:1 as paFer I ',,;ood and coal. ::,'1:'~ade (mostly v~treous) fibers ~ave also been ident~fled in ~:1e sedinent isolated ~ron hu~an lungs, Talc, often used gencro~slj as a dusting :.:;o',,;der I :nay contain a signi ficant amount of tr':::'1O 1i t'2 asbestos fibers. I"formation ~s s~ar5e concerning ~ossib~e ir.cr2ase 0: :ibers in lungs wit~ increasi~~ use of asbestos and ~cnccr~lng ~~e 2::15- tence of significant di:ferences betwee~ urban and rural ?opul~tions. Selik0ff and Ear.;!'"\:J?1c cc:-o:::are:1 lung tiss'J;,s CbtCli:'7:c.. i!1 1934 anc. 2.967 - . and found no sicni:icant ~n=rease in t~e Dro~~r~iQn co~~alnlna. :erruginous DOCl.ES.. This s..::.:-.'~ested 'C:-t2-:, d'2!=pi -:':c ':' .1c:-e2!,in? ~S2 sf asbestos in Ne"l York Clc:.y bet"'l2e:1 ::"934 an: 1967. ,:ibers of a ty~~e producing ferrugln~us bodies had not b2e~ ~ncr20s~~r at a corresoond- ~ng r a t e . Othe~ CS:-1..t~1e!1ta":.c:rs I :10.....2'fier I r-: 1'\;-~ nJ~>~': u~1 2..:1cr~2.S'2 o'.."e!"" each :3.ecadc: 1..:1 :=tsbes::os D8diGS i:l S ?~=:~.. ~:..:s ': ~ .1 .!:Y~':' :r:F~ '''~-r __ ) 50:'1S 'Nho cllCd .cl: I.,oL~1c:1 ~:1 1.936, 1::P6, =-9::6 .1.:::1 .9')(.. A re\Tl!3".tJ of -::hc: and asbestos ex;;cs"..!ro:; pleural ca2.ci::icati:J.!l See Nat'l. Acad., Ex. li.:::.-:=ra-:"Jre r21Ll'Ced "':.'::' .. .!.~1J.":J._:_ st~::-:1~l~- SJ.':;::~SLS ,3.;-. ZlSS... ~~ 7~: 3.nd :18nOCcu-;at..iona~ ::::~":I:J;'J~GS 19, ~. 14, :::;,~1.C.:.:'i::2t-::):-: JL": ~G:':.\?~:-"""l :'0 ac;b::'s~:-:s. c" Industrial experience has shcw~ t~a~ ;r~lc~g~d ln~al3tiJ~ ~f asbestos can incre3se t.12 risk nec::-1.as~i::: ~-::'.r'::': c.cr:::::uCl::--) disease. Exa~ination o~ lung tissue ~~S ~a~~ i~ ~=~ar2~~ ~~~~ 1 r:luch larger proporti::n of t~e general ~ubli::: .1<"..5 l.::hale:; and '-::':.~:.. "'-"'.: asbestos fibers th'ln hael formerly b22:1 r9a::'ize:::'; .il: ~act, -:\'JS:: "'~b'l:' dwellers have so:-"',e s~lch fibers in their 1')."c.-3, The bas:c ~.ss..!~ :'::0- whether the general public, as well as ?2rs::::lS \;::Hki:1? 112ar :::::-:::-.:::-a- tlonal sources, living in the households c: 3sbestos ~or~ers, living in the neighborhoods of asbestos '~lants, ar ~avin~ occ35:~.~'1 ranclon exposures I have a detectably ir.creaS0G risk of na1i :;:1a"..::~' or other disease because of airborne asbes~~s. What l:1for~atiG~ there is to answer these quest.ions CODes 8lther "ro;.: direct eDi::'e:-~~ logic studies of grou?s 'Ni th various levels 0f :1:::>:1occu?ational :':::::')- sure or by extrapolation fron the experience :::>f lndustrlal ~o?~lati::~s with direct or indirect asbestos ex?osures. 3 - 446 . ''''',,>< ') I-iW,J 'I',;o general indices of asbestos exposure arE: available for use in direct epidemiologic studies of groups not known to be occupa~ionally exposed to asbestos. The first is based on knowledge 0:: each member's place of 'Nark and place of residence, Because of the long latent periods of asbestos-related disease, this knowledge must cover each person's whole lifetime. The second is a quanti ta'ti.ve estima-ce of each member's lung content of asbestos fibers. There are fell7 such direc~ epidemiologic st'.ldies, and ~hey are inadequate to a~swer the questions at issue. Of 42 persons 'if: th mesotheliomas reported in PennsylvaniC'_, 10 had worked in asbestos plants, 8 lived or worked close to an asbestes in::lus-::ry, and 3 'vlere members of families -:'hat included asbestos "'O:CKers; in 11, no tisto:;:-y of exposure could be obtained, and the remainlng 10 ha~ ques~ionable random exposures. On 165 fatal malignant mesc1:heliomas known to pathologist:s in Canoda bet\"een 1959 and 1968, an association was confirmed with occupational exposure to Elsbestr::s, but- suggests that the excess \.;as ir. the manufacture a:lc inCi'..lstrial iiJ?\?li::ation <:of asbestos, :::atl1er t...'1an in m::"ning a!"l.a E\illing. It 1-5 apparent ~hat no quantitative conclusions were possible from these studies I "Ihich prssent serious methodologic problems t() the epidemiologist. They suggest a risk in household contacts and lU resijence in the lmmediate neighborhoou of asbestos plants. There appear ::c be different levels :::>f risk in different types of occupa.-::io[1o.l exposures, ar:d some of t.hese may be reflected in corresponding nousehold and neighhorhocd experience. Anoti,er source of evidence of the re':'ative risks associated with ir:halln::; noderate or small numbers of asbestos fibers is the experlenc~ uf persons who have had occupa~ional exposures below those kno,vn to be defini ::el1' hazardous. The maximal airborne fiber concer:t.ratlons recommended for prevem:.ion of asbestosis are much higher L'12.D any likely to be encountered in nonoccupa.tional sit'.lations. Occupation-related asbestosis can be effectively controlled with airbcrne flber concentrations much higher than are likely to be encountered in non-occupat~on&l situations. It is important to determine whecher workers Whose exposures have been reduced to levels that pre'lent or greatly delay asbestosis, as well as others "7hose exposures arE: indiyect, have a lower risk of lung cancer than those with ~igher and more direct exposures. 110st series of case reports of mesothelioma include some persons ~ho have worked in the construction or shipbuilding industries, but in trad~s not lnvolving direct contact with asbestos. Such persons as pluwbers, electrlcians, and metal workers often have more ferruginous bodies in their lungs than do white-collar workers. A study of occupational groups in ~al~fornia revealed an excess of deaths from lung cancer In insulationworkers, but found no excess lungc:ancer deaths in other construction trades. 7here may be a definable gradient of effect within the construction trades. More thorough studies of groups wi1:h indirect exposures are certainly needed. 3 - 447 The mortality experience of L~ose who are ~~ct~ and inQirer.tly exposed to asbestos in their employment is ~ot directlv 89nl~cable ::'0 the general public who have had moderate or slight mcposures froD ambient air. The evidence suggests a gradient of effect from direct occupational, to indirect occupational, to family and neighborhood situations, in all of which dust concentrations are probabl~1 high by comparison v,ri th most community air. This suggests that there may be levels of asbestos exposure t~at will no~ be associated with any detectable risk. What those levels are is not knm.,rn. However, if we eliminate the known occupational, househola and ~eighborhood exposures, we drastically aecrease ~h~ potential for this risk. For this reason our regulations ~ust be directed to emission sour~es and limitations imposed at the origin as distinguished from an effort to establish air ,quality standards as we have done with regard to other air pollutants of demonstrated adverse health effects. Having considered the health impact inherent in asbestos emissions, we now examine the availanle measurement and abatement procedures. Sampling of asbestos fiber seeks to obtain a representative sample of the tota~ air mass in sufficient guar.tity to make quantitative assessments statistically significant. Methods employed in asbestos sampling and the possible sources of error are discussed at length in Ex. 20, Harwood, p. 42 and following. Of the several techniques available for emission sampling, the membrane filter recommended by the U. S. Public Heal~n Service, has become the standard technique for environmental asbestos emission sampling. Air is drawn through a cellulose membrane filter where the particles are entrained. Although the effective pore size of the filter (0.45 microns to 0.8 microns) is larger than the diameter of many of the asbestos fibers, the surface charge properties of the filter and the asbestos fibers, plus the circuitous path through the filter, result in collection of virtually all of the particles and fibers to which the filter is exposed. The collected fibers must be analyzed. This may be accomplished by using a microscopic, photographic or electronic technique to count the fibers resulting from a known volume of air. The fibers which are counted are seen at a given magnification and the number will vary. The standard practice in industrial hygiene is to use a phase contrast microscope at a~gnification of X430. The fibers counted are those having a length of greater than 5 microns with the ratio of length to breadth at least 3:1. The use of an electron microscope would allow all the parti- cles to be count'ed, However, the expense, time and expertlse ~eces- :! - 448 sary to count all the particles makes this procedure impractical. In understanding control techniques and their efficiencies, it is important not to confuse efficiencies quoted on a weight basis with those based on a particle count. Considering efficiency based on a weight basis, it is relatively easy to get a very high efficiency with particles whose size is in excess of 5 microns with a variety of control devices. However, the efficiency does drop off considerably with decrease of particle size. Dr. Han~ood, in his study, considers what a collection effic~ency as high as 99.999% (the percentage of the total weight of Lhe particulate matter which will be collected by the filter) actually means in terms of the number 9f fibers collected. (Ex. 20 , P.47 ). He concludes that 10 fibers actually will pass through the collecting filter for every 1 gram of material impinging upon it. This is a situation not frequently brought out, but is very signi=icant when exposure levels are monitored in terms of fibers per cubic centimeter. Thus, quot~ng of efficiency in terms of mass ) efficiency is a statement that tends to be deceptive. It bears no obvious ~elation to the number of fibers being emitted. However, based on tests ,~hich actually measure the number of fibers being emitted, it would seem that both fabric filters and high efficiency wet scrubbers "are capable of reducing the fiber counts to acceptable levels. British experience is that 0.2 flcc is routine and Johns Manville finds that 1 flcc is an acceptable value when the results are averaged over a time period. - \'ie adopt the two fibers per cubic centimeter and the over five micron standards because of the facility of both abatement and measurement ut~lizing these numbers and because they furnish a sound indication of asbestos content in the air. However, recognition that particles of smaller. size may have adverse health consequences of equal or greater magnitude will require the Board to review this subject periodically in consideration of the available measurement technology. See Ex. 6, Lynch, Ayer and Johnson, "The Interrelationsh~ps of Selected Asbestos Exposure Indices,"American Industrial Hygiene Association Journal, September-October, 1970, p. 598. (The direct index of asbestos fib er exposure proved to be the concentration of fibers longer than 5 microns. See Ex. 27, Edwards and Lynch, "The Method Used by the U. S. Public Health Service for Enumeration' of Asbestos Dust on Membrane Fi Iters," U. S. Department of HEW. 3 - 449 Consideration must be g~ven to available con~r0: techciques, the fabrication and use of asbestos containins rroducts and exposure resulting from activities involving asbestos emission potential. Because of the demonstrated alternatives to asbestos spraying, our "egulations will flatly outlaw this activity. S~raying of non-asbestos materials are perm~tted subJect to stri!1gent protective measures. Air ventilation systems can be employed to minimize emissi0n during the mixing of fibrous fireproofing and insulation materials. HOOGS can be provided at bag-openlng and emptying areas. The mixinq area, if not totally enclosei, should be ventilated. Conveying equipment, to and from the mixer, can be enclosed. Bagging of the mixed material should be done under suction hoods. On-si~e controls needed include enclosing the area to be sprayed and eGploying good housekeeping procedures both 6efore and following the spray operation. The filling of the spray machine hopper must be done carefully to mini~ize dust. When the machine is not in use, ~~e hopper should be covered to preven~ the material fro~ being blown about. Several states and manufacturing associations have published guidelines for emission control. The recow~endations include the following: 1. All areas used for o?ening bags containing fibrous lnsulating materials and charging of noppers should be enclosed. Empty bags should be properly disposed of. 2. Floor areas should be swept broom clean before spraying operatlons begin. All unnecessary objects'~n the spray area should be removed or covered with plastic or plastic coated tarpaulins. 3. The entire area to be sprayed should be enclosed with plastic or plastic coated tarpaulins. An enclosure will be considered satisfactory only if visible insulating material cannot escape from the closure. 4. Fibrous-containing material b~at falls to the floor should be swept up immediately and placed in approved disposable containers. 5. When spraying is completed in an area, the entire work area and the materials used to form the enclosure should be thoroughly vacuumed. The vacuum cleaner should contain a strong, single-service, disposal inner bag whlch shall be removed from the vacuum cleaner and sealed. Disposal is the same as for other bagged waste materials. f;" >,"\. w "et..>} 'v~jI~' 5. Any plenum or o~her stracture coated with asbestoscontalning insulation ana intended for circulation of air in the building must be thoroughly cleaned of debris and waste. Fibrous insulation in a duct or plenum must be coated with a sealer to precl~de erosion of t~e insulation by circulating air. Our regulat~ons e~ody the essential features of these suggestions. Asbestos emiss~ons are likely in any process in which asbestos flber is handled or asbestos-containing materials are cut, drillec, or trinmed. The quantity of asbestos dust generated by these operations can be quite large. Since it is impractical to completely seal a factory or a work area, industry has adopted an arrest-a~ the-source technique for capturing this dust utilizing a complex ver,tilaticn system comprised of cajJture hoods, ductwork I fans and fil~ers. Benefits received from this system include: 1. Reduced atmospheric emission When plant is open to ambient conditions (i.e. f doors and \,Tindov,Ts open) . 2. Reduced external emission from fibers being carried outside on work clothing and manufactured products. 3. Greater efficiency 1.n plant operation because of reduced internal hOUsekeeping chores (vac~uming, etc.). 4. Better personnel attitudes. The ventilation system may eliminate the need for personal respirator units which limit efficiency and are generally disliked by '>lorkers. The air ventilation system 1.5 an integral part of the emission control o~ogram and the components of various systems in operation will be considered. Two types of ventilation systems are employed for dust emission control; low volume, high veloc1.ty; and high volume, low velQcity. Each requires a specific type of hood design. The low volume, high velocity systems induce an extremely high captive air velocity, 10,000 to 12,000 ft/min., at the dust source. The air volume, however, averages only 10-250 cfm. With this system it is essential that the feed particles be carried by the alr stream. The entrainment force must exceed the gravitational or projectional force. LOVJ veloci ty, high volume air ventilation systems, on the o~her hand, are utilized for operations where localized capture 15 J - 45i not possible. Por such hoods ~o be effective, the air velocity to the ducted area must be at least 150 ft/min and should be suc~ that the air flow direction is ahlays tm..ara tl:e collection system. A considerable amount of ductwork is required for a large plan~ having a central collection point. Cir~ular ducts, havl~g no sharp bends, are recommended. Inspection ports should be provided near bends. Several types of collectors have been I1tilizec1 by 'Che asbestos industry for dust control. Baghouses represent the most frequently used filtering system. Wet scrubbers are also used. Cyclone precipitators may be used as primary collectors preceding baghouse filters. Electrostatic precipitators tried by the asbestos industry have several deficiencies. Asbestos is an insulator and builds upon the electrodes reducing efficiency. Installation costs are higher than for baghouses. An electrical failure vwuld remove all emission control. The most commonly used filter system is the fabric filter. This device .is found in a wide variety of forms from highly sophis- ticated systems containing thousands of bags to crude devices con- taining homemade burlap bags. The baghouse is compartmentalized to allow continuous operation by alternately cutting off sections i for cleaning while other sections contlnue thelr dust removal func- tion. The bags are "cleaned" by a mechanical shaking action, either by a shaking floor or, more commonly, by a shaking support. Hore elaborate cleaning systems such as reverse c:lcle air jets or sonic systems have not been considered worth the extra complica- tion. The baghouse unit is frequently located outside the fact:ory building to conserve space. Usually the filtered air is exhausted to the atmosphere. In some cases it is returned to the factory to conserve heat. This air contains some asbestos fiber~ since no control technique is consldered to be 100% efficient. Waste products collected in the baghouse hoppper are removed by hellcal screw conveyor. Design of the hopper emptying mechanism should provide as foolproof an operation as possible. Severe pollution can arise if the mechanism lS openea for repair. Other collection devices used either in combination with fabric filters or alone are various types of cyclone.separators. Low efficiency cyclones are used in the asbestos industry as first stage separators preceding fabric filters. They are useful when the waste product is reusable and there is a conside~able quantity present. Thus, the load on the fabric filter is relieveci. 3 -452 Further, the removal of heavy abrasive waste material will prolong the life of the filter bag. High efficienev QTclones are generally employed in multiple units. They are used where high efficiency is required and where no use is made of backup fabric filters. Wet cyclones are employed as emission control devices in some special instances where wet proceSSes are used for production of asbestos products. Although generally not as efficient as bag filters, chey eliminate the problem of filter blockage caused by condensation. The fans which provide the air movement through the dust collection system may be mounted either upstream or downstream of the filter system, the most common arrangement being downstream. This places the ventilation system under a negative pressure assuring that ambient air will be drawn into the system in case of leaks, rather than dust and fibers being exhausted to the atmosphere. All asbestos product manufacturers are faced with the problems of storage and transportation of bagged asbestos fibers. Emission controls for these operations depends to a great extent upon the conscientiousness of the individual user. Manufacturers should provide clearly defined, clean, dry storage space for the bags where they are protected from accidental damage. A rotation system should be employed to ensure that older bags are used first. Damaged bags should be placed in larger slipover bags and resealed. Small tears in bags should be patched with tape. Jute bags are permeable and will allow fiber emission. Kraft paper bags are liable to tearing when handled roughly. The best compromise at this time seems to be bags of coated, woven polyolefin. Bag storage and the bag openlng areas should be as close as practlcal. Fork-lift trucks are usually employed to transport the bags between these areas. The route used by the trucks should be smooth surfaced and free of obstructions which might cause damage to the bags. The bags should be opened in a hooded area using a sharp knife to slit the bag. Pressure packed fibers will hold together as a u~it and can be slipped into an enclosed conveying system where they are transported to a fiber opener (willow or fluffer). All conveyor systems transporting asbestos fibers or mixtures of asbestos and other materials must be completely enclosed. 3 - 463 '".. ~,'\ , I .,,!#v' The eID?tied bQgs also present an emission source. Care must be '~aken to di spose of them. Since there are few manufacturing processes which will accept paper bags as part of the process, asbestos paper being an ex~eption, they are usually bundled into large polyethylene bags and taken to dumps for disposal. Plastic shipping bags can be similarly utilized in some manufacturing ?rocesses as the =loor tlle industry, for example. A possible source of emlssion from manufacturing processes is Lhe ~ransport of =ibers outside by the workers the~selves. The control of G~is source of emlssion to date has not been very satisfactory. At best, booths are provided where workers may clean fibers from their clothing. The booths are equipped with extraction fans i~ the ceilina and a flexible pressure hose. SucLion hoses would be oreferable ~ SepaL'ate lockers for work and street clothing is suggested. ~ee Ex. 9, Cralley, "ICentification and Control of Asbestos Exposures", _~erican Indus~rial Hygiene Association Journal, February, 1971, p. 82. Ex. 18, "Recommendations for Handling Asbestos", Engineerlng Equipment User Assn., No. 33, Rev. 1971. Ex. 13, "Recommended Health Safety Practices", National Insulation Manufacturers Association, Inc. Demolition and waste disposal are likely to be emission sources if appreciable anounts of asbestos are used in construction, unless o?erational procedures are strictly controlled. Isolation, enclosure, and wetc:.ing down are useful. Caution must be observed not to der.lolish during hlgh wlnds and to keep sludge from drying out and becoming airborne later through natural forces and from being introduced into sources of drinkin-g water. The subject of disposal of asbestos vlaste must be examined. Recycling is possible if a plant has a fil~er-ventilation system. But the effectiveness of recycling varies with the kind of processing. If a product such as water pipes is made in which asbestos is mixed 'Ni th cement, a chemical reaction occurs making re-use of much waste impractical or impossible. If asbestos paper is produced, much airborne fiber can be collected and re-used. However, virtually all manufacturing of asbestos products can involve some recycling. The dust collected in the filters, the "short fibers", can be reused in the manufacturing of transite pipe. This pipe contains mostly long fibers used for their strength and thus, only a limited illRount of the "shorts" can be mixed in. Recycling is especially feasible for large companies which manufacture transite pipe as well as other asbestos products. In this case, recycling is profitable as it involves only cleaning the filters and transporting the "shorts" in the area of the plant or to the division of the company which manufactures tranS:L te. Recycling does not appear to be relied npon as much in plants which do not produce transite. In such case, the company 3 - 454 I,'oulc! nave to 32J 1. i -:s s~ort f.:..ber-s. Vie cia net ;'~now how great the c1ema:',d is. Hor do "re k!1O'N the percentage of col.i..ected fibers whlch can be re:::ycled under opL.mal economic conditions. Joh!1s-Manville ir.. hJaukegan ::lai:ns t::l re-use "most" of the filtered short fibers. ~~t It ;nanufact~re~ tranSitE, bra~e linings, sheet packing and 9 as;zets 1 \-lhi cn f aci 1i tates and makes cheaper the use of captured fiD2rs in truns~-:e product:on. Generally, the asbestos collected thro~gh the filters or swept up lS oispcse6 into plastic bags. A special disposal procedure is followed by some manufacrurers of asbestos paper products. Water lS useci in the production, which picks up asbestos fibers a~d is then 6ralneo o.:r i:1to settllDS F)nds. The heavy materi,,-l settles out and t~e "tJdter is then channelec1 back to -the plant for re-use. 'file sludge is at the battoD of the po~d a~d is shovelled up and dumped. The na-':.erial ~s not buried. ~e do not know if a~y factory directly or eventually discharges th::'s "later in::c na':.'Jral. ,:ater flov,s or sewage systems, ",hich could 0050 a considerable hazard. Th~ Johns-Manville Waukegan plant uses ~ pend syste~, but the water lS recycled. While our regulations are enacted in the context of other governmental controls of asbestos, they necessarily go beyond these regulatlons to deal with significant emission sources not covered e~sewhere. The Federal Envlrenmental Protection Agency proposed asbestos 3 ta;-tdards on Dec8JrJ:Jer 7, 1971, under its authority to regulate hJZClrclous air pollutants (40 CF~, Part 6). All emission sources which exis:: in Illinois and which are proposed for coverage by che Federal E~vironmental Protection Agency are covered by today's rccuiation. Also, our regulation covers waste disposal and water pollution; imposes procedural safeguards for construction and uemolitioni and sets a numerical emission standard in addition to 3. "no vlsible emissl::m" standard for manufacturing eraissions beyond thE plant. 'l'he I1IJ.noi5 Department of Laber adopted the recommended safet), sta:tdard :::>f the American Conference of Governmental-Industrial Hyg:cen:csts for "in-plant" air. The regulation we adopt today dces not control the leVels of asbestos inside a plant, largely an occupatlonal hazard beyond our jurisdiction. Insofar as this goard's regulation affects what transpires inside a pla~t or on a construction slte, the impact is merely incidental to the relationship between certain "in-plant" activity and a significant hazard of air pollution beyond the siee of such activity. For example, Sec. 201(c) requires that facilities be provided at the work site to prevent the removal of visible amounts of asbestos from the site on-the clothihg of employees. The evidence shows that human transport of asbestos fiber is a health hazard to those cOIDlng into contact with asbestos workers beyond the confines of the job. 3- 455 ..:,VT<' '>v: :\ ,,;.:k( The Illinois Department of Labor also adoptee procedures for enclosure and cleaning of construction sites, on which asbestos is sprayed. These procedures were intended to protect the health of workers on the si te, although their effect, i'f pursued, would be to reduce em~ssions to the ambient air. The record shows that such procedures are cumbersome, seldom obeyed to the letter, difficult to enforce and insufficient when obeyed to protect the public beyond a construction site. Hence, we have banned asbestos spraying. Again, the impact which this Board's decision exerts on the actions of another state agency is made necessary by our mandate to protect all members of the public from air pollution. A similar ban on soray asbestos has already been taken by the Cities of Chicago (effective January 1, 1972), and New York, and is being considered by several other cities. In consideration of the foregoing factors, the Board submits a comprehensive regulation for asbestos controls. To this end, the regulations identify the significant contributors of asbestos as the commercial use of asbestos in construction work; the demolition of asbestos-containing structures; the manufacturing and processing of asbestos-containing pioducts; the transportation of certain asbestos-containing products; and the disposal of asbestos-containing v;aste. The use of asbestos in brakes, \"hile originally included as a subject of control, will be deferred for the time being. Part 11 of the regulations imposes several general requirements upon all commercial construction, repair, alteration, demolition, manufacturing or processing activity from which asbestos flber is discharged into the ambient air. The persons responsible for manufacturing activity must obtain a permit from the Environmental Protection Agency. The permit system will serve to produce the advanced assurance of compliance with the applicable control regulations and will thus reduce the cost and burden of in-the-field enforcement. In addition, these commercial activities must provide facilities to prevent the removal of asbestos fibers from the site of such activity on the clothing of employees. Indeed, this poses a rather new concept of. air pollution control. Those I'ho have died from lung ailments induced by long, close association to an asbestos worker may be powerful proof of the need for novelty. Finally, the Regulation would provide for careful waste disposal procedures, as wind-blown refuse heaps and scrap piles contribute to the volume of asbestos fiber in our air. The simple steps for control eliminate any excuse for such dangerously sloppy hOllSe'tlork. :1 - 456 Ir.. our final d~afL., t:1e pernit require:-,en-:: of Part 11 nas been res-::ricted t8 ~anufacturing emisslon scurces. This is in accord with the Agency testi~ony that presently it has lnadequate staff to handle the permit load created by a blankeL requirement. All man"Jfacturers of asbestos ?:Loducts must. obtair. a Demit by June 30, 1972. Part 111 ~rohibi~s t~e spraylng of asbestos-containing ~nsula tlon and fireproofing. Experience has indicated that procedural safeguards are i~adequatc and their enforce~ent is an overtaxing burde,.. ProceGural safeguarjs deaigr.ed to reduce fiber eDissions would be required to spray non-asbestos insulation. The biological effects of these fibers is unknolrJn. Prudence \lIould seem to dictate reasonable efforts to soften the potential future blow from spray fiber as~iring ~o asbestos' status. Part 111 requires ~1at various asbestos-related activities at cons=ruction sites be done withln an enclosure. It would also r2~ulre that asbestos constructio~ products be so installed as to ?recluce the emission of fiber into the circulating air. I~ ~he interest of eff~cient enforcement the numerous restric- tions on the s?r~y:ng ef non-asbestos fibrous ~aterial have been reduced to recui~e~ents for e~closure and for vacuuming. Also thIS -,:- section has b~en changed to ~ake clear that these safeguards are required only ~hen s?raying of non-asbestos ~aterials occurs in an al~ea open to the 3tflosphere. This "open to t:1e atmosphere" modifica- tion has also been added to tje section controlling the cutting, tri~~ing, fitting or strIpping of asbestos-containing ~aterials at a construction SIte. Part 111 now contains a "no visible emission" standard wh~ch must be ~et regardless of adherence to the required procedural safegLards. This should permit easier enforcement and tend to insure greater compliance ,vi th the safeguards. The original proposal contained two regulations controlling the general application of asbestos-containing materials and the application of non-asbestos ~aterials in air ducts or plenums. This has been altered to require that only asbestos-containing materials, used in any construction work, be so installed as to preclude emission of the fiber to the circulating air. There is little medical data available to prove or disprove the toxic effects of the ~ulti~ude of non-fibrous construction material, although one such product, fiberglass, would appear to be biologically inert. The Board prefers to act on the safe side of health in regard to spraying operations, which can emit large quantities of fiber if uncontrolled. In any event, such uncontrolled emissions constitute a nuisance dust and could be controlled on that basis alone. These reasons do not a?ply with equal force to the non-spray application of non-asbestos ~ateria~s in construction. 3 - 457 _-\! ,!.,v...... ,~.;r ) Part ;'V expresses t iro:llcally, what !T_al' be a key reason for bann~ng sp~ay asbes~os. It ~ould require that procedural safe- ouards be purs~cd in order to demolish a structure wiose destru~ti8~ 0= ';'culd ether-wise exp::Jse merr';:;ers of tl-:e !Jublic to asbestos fibe::. Clouds dust are often raised by aeDoli tion wor:~. ThE tact tha~ great numbers of pen::ons may be ex:;.'osed to Lh:.s dus-:=. i:1 urban areas and "Chat tl:e 90st-war sreneration of :>.igh-rises ":/ere the first bUlldin..;s to use asbestos lnsulation extensively speak ~n favor of SUCD regula- tion. Part IV is intended to require an enclosure only ~hen necessary to prevent dl.spers':'cr: of iust durlng cl2:nolition and only an 0,=enclosure which is :.easonab:'y compatible ",7ith the s::rUC::\.lre tc demolished. In some cases, tota':" enclosure can be +:easiblv achie-J(;(:. With other str~etures, a around le?el enclosure ~ay be the li~it ef co:npatibili""Cl' . Part V, controlling Qanu~acturing sources, js cha~ged t~ requi re ar. emlsslon standard of two flbers per cubic cel; tlrneter and no visib'::'e emissions. f,.;rhile so:ne testl7nOnV indicated the difficultv in measurinq compli.ance <.lith a nur:terical e;issicr: standurd, overall-, the eVldcnce establishes bot~ the neec (protection against tl1e qreat proportion of invisible fiber) and the ease of measur~rent of such a criterion. 1', lino visible 2!11issio;J" standard has been adde,~ to the numerical standard to siDplify enforcer.1ent against exceptiona::!.ly dirtv emission sources. A grace perlod, until June 30, 1972, has been adde~ to permit acquisition of the necessary control eq~ipDent to attain the emission standard. References are :nade to ~he method to be used in collecting and counti~g em~ss~on samples. The sa~pling ~etho~ is that generally used i~ sampling particulate e~issions. The counting ~ethod lS ~~a= reliably used by the U. S. Public gealth Service. A requlre~ent has been added, at the Envircnnental Protection Agency's suggestion. tu channel all asbestos emissions inside ~he plant through control equip:!1\ent and to exhaust such eElissions throu')h points '",here samples can be taken. This is intended to prevent venting through windows or doors or other avenues of escape on w:1ich sa~pling cannot be adequately performed. The Aqency is also given the power to inspect manufacturing premises at reasonable ti:nes tc determine compliance. Also, the manufacturer mus t engage in moni-toring and reportlng. The latter two additions are in keeping I",ith the Board's practice in most areas of regulation. The waste water discharge provision now requires ne discharge of process water to which the manufacturer has added asbestos unless best available treatment technology is first u~ilized. 2 -- 45B -'''.''''''. ~.} '.;;;i#' t~ II:J,:) \7isib2..e e!1issio~" ~o~tation regula~ion. star.dard 1. ... _ .... .1.0'::' been added to "Che t.rans- The emissiO:1 standard would measure only ~ibers longer than flV~ ~l=~ons. The Ju~tificatl~~ ~~r this see~s to be the adminis ~~3~!V~ c~nveni~nc2 of avoid1~g d1fficulties in ~easuring fibers ~r~:, .5 ~c five ~icrcns in lenqth. So~e medical ~vidence has in~lc~~ed ~hat ~he very s~all fibers ~ay be the most dangercus. The 2c:;.:cci ''':111 conL_!1L:e to exa,'":11:1e :'.1e :-:tedical im?licaticns of +.:.he sub:: \.\'12 ~i1i:n):1 fibers and t.he means of rleasnrement and control. Part. V, Sec. 501(a) - has been slightly Gcs'2ci f ~ DJl draft to add the ~hrase "into t:he :..:.' :.:"ke c::'ear that the err,ission standard does ;-Jlant atr'os~here. changed from arrlbient air" net apply to the proin order the in- In rart. V, Sec. 502 - t~e word "enclose" ~as been changed to "'.:-:-;-::.r01 " ::J:, ~he 5ucrgesti:::>;1 t!1at as p):eviously '/Jritten the :neaning ,,'itS .,;n.::1c,n 2,nu i. "1])lieC t o t a l enclosure of a l l f a c i l i ~ies. O~r origl~a] ?rcposal would ~ave prohibite~ the use of brake linIng In ~~~iclQS ~an~factured after January I, 1975 and sold ~0~ use ,l:l I ::'linols. it -,!as Delieved if brake lini;19 decor:lposi tior. '2T11t::; 3sbcstos :i!:l2c, t:1en t.h? tre;nendo'Js number of vehicles using ,'\sbes-::.::Js, O,b ::hc J -',' r.o:\cLi cdblli ty of controlling these n..EnerO'.lS 3~a:l ~~i5Sio~ scur2es ~ould appear to speak ~o the need for a 9roc~;.:ct ban. ~his nro~osal to ban asbestos brake lining has bee~ dropped for -::.he ti~:1e Oe1:1S. -'ihlle the evidence sho',vs that brake lining ciecomposlLlon 15 a slgn~t1cant source of background levels of asbestos, these a:~.!)ie:Jt air levels a Le (;ui te small and have not been shown to be a heal-::.h hazard (al though t:1ey have not been shown not to be). In aJjl~lon, adequate alternatives to asbestos-lined brakes are not yet ilvai J ab le, al thO\.:Sh closed brak1ng s1's terns, preventi nc; the e:niss ion of asb~st~s d~st,are ~ossible. The Board will follow the :nedical and eng1Deeri~g as~ects of this problem and possibly may returr. to . FLna11y, local govern:nents are obliged to enforce t.hese regulations, except for the manufacturi;1g rrovisions. !1uch of the problen arises rOl-:\ nUfi1erous cons truction acti vi ties, and the Agency cann::>t adequa'Cely supervise these I'1any e~ission sources. The "no visible emission" standard has been added especially to facilitate local goverlL-:len.t and citizen Clssistance in enforcement. U (j I, Christan ~offett, Clerk of tte 1111noi5 Pollution Control Board, cert1 1' that the abovE Opinj on 'Nas adopted on the l,-If) day of ~' . ~IY)~ 197~b\"'I\'ot( or-l-n.