Document Byq9V6OxkGyEj6OmYaNboJ2B4

FILE NAME: Z/ZZZ/Ed DATE: DOC#: /Ed DOCUMENT DESCRIPTION:DZZ/ZWZZ/ ^ZZZZ Z" EZDZZZZZ Z . . '. .~ .. ,.. '. *.. I , Iu,G.~..: -r~-. \~J ana TC: ~r. John H. ~~rsh August. 22, 1978 SUBJECT: Asbestos International Association lbe Most Icport Points to be Included in an Industry Statement en Asbestos and Health Problems I r.ave read P~rry Rhodes' letter to you dated August 15, 1978 and note his concern about my attit~de to\oard what triggers the medical surveillance of asbestos workers . I have also re-read the .sections in the Excerpts from the Asbestos Industry Response to OSHA dated April 9, 1976. !t i3 not my intention to insist upon unnec~ssary medical examinations, and I think that. the "inse.r-tion or the word "occupationally" in the 3rd line ot' item 6.3 en page 2 between "employees" and "exposed", will considerably nar:-cw the field. I am cer~ain that the trigger for medical examinations .should be "occupational ex;>osure" and not over-exposure implied by limiting the sur1eillance to those "persons regularly exposed to airbcrne asbestos fibers in excess of the prescribed :staneards." The vie"Point expressed in the AIA document that it b unnecessary j to keep under surveillance per3cns exposed to asbestcs below tne prescribed standard is not a valid one in the light or the acceptance by the industr1 that the exact level ror the prevention or cancer has not teen ~emonstrated. It is essentiii- to build up dat.3 on low levels of exposure and, therefore, all "occupation~lly exposed" workers should be exa::U.ned, res;ardless of fiber count. At the same time every effort should be made to insure that adequate records are made and kept, shc~ing the type of exposure, duration of exposure and intensity of exposure for each individl.:31 to correlate with subsequent medical parameters analy:ed. If the asbestos industry wanted to cake a positive contribution, the develop~ent of a viable tee tnique for auditinc; the applicability of the provisions of the standard to v.J.:"icus jobs and cperaticn~ would be of i~..C'lense value to ~orkers, industry IJ t1:P~:,,_J;.. and reg~lat.ory agencies alike. Hilton C. Lewinsohn /a!?. -.L c:.. c..:;., "" '-,'..'....:'\~ -- ~; ,/ , ' J, ,...... ME."10 f rcrn the desk of OR. HILTON C. LEWINSOHN N.~ \u4.t ~ ,3 lk ~ ~ \bo ~ 'ec~ ". fu,.; .. te~c&~ ~~~ O.J.4P ~ tfie ~ u.,~ l!i.d~cO ~ ~- {f.J. ~ ~ ~ .~~ ~ cU' ~ e~ Lu>& C. a\~~~ ~t4 1k1 ~ lLo J-tl ~ ~ ~ ~ ~ ~ w~Uu&~ , ~~~- ~g/17 JHM 07705 . ..,., . .. ' . \1.,'01u~ , .. t'\ ..h .. ... , UNION CARBIDE CORPORATION METALS DIVISION i>. 0. BOX 579 NIAGARA FALLS, N.Y. 14J02 TH: 716-278-3376 August 15, 1978 Mr. John Marsh Raybestos-Manhattan Corporate Headquarters 100 Oakview Drive Trumball, CT. 06611 Dear John:. I see only one serious difficulty wi:h Hilton's corrments on.my 7/31/78 Draft (attached), i.e., with Item 6.1. In their response to the October 9, 1975 OSHA Proposal, the AIA/NA took! strong position that there was a minimum exposure le'lel below which m;dical examinations should not be required. This position was based er. the lack of medical usefulness of such examinations, the inefficient use of limited medical resources that would be spent giv1ng such examinati:ns, and the practical infeasibility -of actually providing the number of ;xamina,tions annually which would be required. It is my understanding that this is 1lso to be our position in the forthcoming OSHA asbestos rulemaking. Ar. industry position that all employees exposed to asbestos" should be suo::ct to routine periodic medi~al surveillance would seriously underc~: this approach. If we have a problem here let's discuss it as soon as pcssible. Regards, ?~ Harrison B. Rhcdes Technology Manager HBR/r'.iTTl Attachment JHM 07706 ~ ..... . ..... . DRA F T HBR-7/31/78 ASBESTOS HlTERNATl ONAL ASSOCIATION lHE MOST IMPORTANT POUHS 10 BE INCLUDED IN AN INDUSTRY STATEMENT ON ASBESTOS ANO HEALTH PROBLEMS w 1 II nr.t- 1. Asbestos, like many other essential raw materials,~ be a danger to health if it is ~correctly used. 2. Cigarette smoking has a strong synergistic effect in increasing the of- lu.r',:1 r~(~ . ~h risk from exposure to asbestos. A 3. Industry believes that a time-weighted average exposure of 2 fibers/cc :>5"'(..i s P"-~'- i"'""'r,.J h1g.erie ar-Ji: appropriate standard but recognizes that ' there is A ~ b1clu~lcol oLff.t~ no conclusive evidence to ei t~er prove or disprove 0 s pp'" ?>J3 ; ake11e.!!s- q' ~ this level. As a consequence of this uncertainty, exposure should be controlled to the lowest practicable level. 4. There is .a long tirre interval between exposure and appearance of ~117 . disease and present cases are associated with levels of exposure in the \14"1<~ "-'"'~ A past greatly in excess of those experienced in properly controlled /\ modern operations. I .. . 5. Industry recognizes "the need to control wel'iter exposure to asbestos and favors strict enforcement of realistic regulations in coopera~ion ~1)4""'""'...t o .. f\4,o,,"-cf > .~ ~ / ~ ~ o-.A L,;. ~ M~"' with f'j:..i:_ 01:1tno1;t;es 1 -1Pedical p 1 c1ess;onah. and trade unions. 6. Indusit!.rytu ~w&.i1Q 1Q.Ucj on~inue to take all necessary actions to ensure safe and A healthy working condi ti ens. ClM.tl ~ ~ "'"'J..~" ~ eMo"....,..tJ rll....h." 7. The user of asbestos-containing products is generally not at risk if there ~re no subsequent f;ni~hing operations which .generate exposures above the limit noted in Item 2. If there are such finishing operations, . 4Shfu~bf ~'1 l' iNu~h~ ,~ 11-l f..\...l.u.~t..,A PJ 1---~ w the necessary precaution~ must be taken. n<J f~ l\.u ~:"""'.; ,I\ If',.> 11~;z~>f' 11\ai- /\ 8. ,. . ~sbes tos in the ar..bi ent air does RGt risk/ to the co~unity at 1arge. .. I . : ..... .... RR ~f. !. ...... HBR-7/31/78 ASBESTOS INTERNATIONAL ASSOCIATION DETAILED STATEMENT OF THE INDUSTRY'S POSITION IN RELATION TO ASBESTOS AND HEALTH PROBLEHS 1. THE ~ISK TO HEALTH 1.1 Asbestos dust may repre~ent a .~?nger to health if it is inhaled. 2. ASBESTOSIS . ,, . 2.1 If sufficient concentrations of fibrous dust are inhaled~ . ,.c,.,.._ 'C'.!CS : 19relcm5;d periods, fibrosis cf the lung (asbestosis) may result.-{ lc:a."-Ew ~ 2.2 Cigarette smeke!'"S ~ho are exposed to a5be5to5 a-re-more- ~:~J . ~u~,c~e~p~~i~b~l&e~~~~Q;)_..l:t~b~i~s~r~i~'~k~th~auR~~~~c~n~s~JReA&ilk~e~~s~. ,~ .. . 3. LUNG CANCER ~~OM qo~ 3.1 Asbestos workers eo aot _e_m to b! more susceptible to lung .,_ ;.. w~u f\e.t ~ u _ cancer than other people t:iA1 e" tt:iey smoke. fto.f wc<l with Oibe.J\ts. ~ ~~ ~ (LQJ.- ~ ~ 3.2 Asbestos workers aP& ad: ised not ~smoke or tlr reduce their J. A srr~king to a minimum because smoking (particularly heavy smoking) considerably increases the risk of developing lung cancer. 4. HESOTHLIOMA .de6C?- reJ ~e. 4. 1 There appears to be a ~relationship /\ between exposu.r.e..to.. . ..... .. -- asbestos and the 1nci d_ence of mesothel i cma:-i::q::t ~t al1 cases of mesothelioma can be associated with exposure to asbestos. 4.2 While so~~ medical authorities take a positive stand, there is f'\Jt 4 pa': wl: .- by no means general agreement about the al l_eged~ Sf'~;;,: tjf~ ~ ~ ~~ ~ of crocido11te and amos1te 1n the causation of this disease. ~". J The ma.jor1t y of Assoc1.a t.1on rnembcrs who current 1y use l!. take the II A view tha~ <~1"w"~:b>r"...= .c.- ~ can ot11:4I Id~ ~He used proviced that the .. ~.., ,.r,~ C"' precautions ~et out.inl\the Associ~t1cn's publicaticns are strictly J H ~./\ 0 7 7 0 8 F . . ,,. .. .~ ; ,,., . . ~ -2- 5. REGULATIONS AND THRESHOLD VALUES 5.1 The industry accepts the need for statutory regulations designed to ensure that asbestos . is used ( 'c I I .e safely.~ ,l., ~) ~..._t;; J! 5.2 It is the industry's policy to r!aa1 ws;d;:t exposure to airborne ,A. asbestos fiber during manufacture to the lowest practicable level but in any case not to exceed the 2 fibers/cc limit. - 5.3 In the absence of regulations in any country, the Association reccmnends that the precautions set.out .in its.publication 1he Control of Asbestos Oust" should be observed. . f ....... . 6. MANUFACTURE 6.1 Asbestos may be used in industry provided that the dust control measures recormiended by the In. ternational . Association are observed. 6.2 It is the industry's policy that all of its employees should be fully ~nformed 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 '. ~ ~ is used are monitored in accordance with the regulatory requirements . . . oc.c~ of the country of use and that all err.ployees exposed to asbestos a'" ~c!en: I el S"'c.r..tJL "'- /\ a"'c 1e "'h' , .. t:L1J l..sel ~ subject to routine periodic medical -. surveillance. 7. USERS - -...:. .. 7.1 If there are no subsequent finishing operations on products which release significant quantities of airborne fiber. it is generally ac~nowledged that there are no health risks to the users of the products. I -i If finishing operations are undertaken, appropriate precautions ,...~ ~~'( ~ ~ w-u ~~ ln WM{}~/~. H-d-s .. .,r: ...,..;u. "''"a .l.pe, of fiber re1o.4GEH~- :i11tt lu elnl!.wed. 7.2 Full information about possi~le hazards should be given to .. . users of asbestos prt>duc!s. . .' . ~I -3( "' 7. U~ERS (Continued) 7.3 As yet there is no unifonn policy concerning the use of warning labels on asbestos products but many members now believe that the industry should voluntarily label products where a possibility of significant user exposure exists. 8. MEASUREMENT OF AIRBORNE DUST 8.1 It is the industry's policy to take the lead in the develcpment and standardization of reliable techniques for this purpose. 8.2 The industry recommends that the membrane filter method be I retained as the standard method of measurement of airborne concentrations until bette~ alternatives have been tried, : and correlated with it. 9. GENERAL PUBLIC CJ:N>4~ ~ ~ ~ bl k .. 9.1 The general public is not at risk from asbestos or asbestos products. " 9.2 Personi living near asbestos factories are ndt at risk provided the precautions issued by the International Association are 1 properly observed.~ ~ ~ 10. RESEARCH - ~' ~ ~ azw.~~ ~1"r'.~ ~. P'~ . . ~- . -'\ . -- ~~- ' - 10.1 The industry supports research into medical and scientific questi~ns associated with asbestos and asbestos-relat~d disease. : - .. :;~ 10.2 The industry encourages publicaticn of the results of this research irrespective of whether these results are favorable to the industry or not. J H 1\1 O77 1o .( { l u . 1 11~ ; ' d