Document ByMkv5xOB2YDdMdgxVKXErwL4

UC' 149-2 INTERNAL CORRESPONDENCE jzr,r, PLAINTIFF'S EXHIBIT UC-3915 METALS DIVISION To (Nam*) Division Location Mr. T. W. Carmody UCC - HS&E Affairs 270 Park Ave. - 11th Floor New York, NY cooy to Messrs. R. F. X. Fusaro '+T L. Myers W. C. Thurber File P.0. BOX 579 - 4625 ROYAL AVE.. NIAGARA FALLS, NEW YORK 143 Data February 21, 1978 Originating OeDt. "Calidria" Asbestos Answering tatter data Suoject ORC Generic Standard Proposal of January 19, 1978 Dear Tom: The above-noted proposal has been reviewed. Although improved over the previous version, it continues to be grossly lacking overall. Detailed comments are as follows: 1. The sections on Secretary's Responsibilities, Carcinogen Classification Commission, Criteria for Classification of Carcinogens, Determination of Permissible Exposure Limits, particularly the latter are worthwhile and generally well written. They appear, however, to be somewhere between a popular argument and a technical presentation. The AIHC is much more the former as it should be for a document of this type. It is assumed that they will be supported by detailed testimony at the hearings. 2. On pages 5 and 6 of the suggested standard, classes of human carcinogens are expressed in terms of excesses of cancer or neoplasms. No consideration is given to the dosage required to cause the corresponding incidence of cancer. 3. No use of risk/benefit in setting levels is included in the approach to setting standards. 4. A finding of a human carcinogen triggers an ETS if certain conditions are found. These conditions include a finding of a grave danger with no remedial action. No definition of what kind of remedial action or how effective it must be is given. A demonstration of technical and economic feasibility is also required. These take months to years and would effectively prevent any such standard being promulgated. A08741 UCC 014192