Document GX879wxbQjBobRZMX6V2Baxv

UNITED STATES DISTRICT COURT DISTRICT OF NORTH DAKOTA SOUTHEASTERN DIVISION ANDREW HENJUM, Plaintiff. ) ) ) . vs. ) ) The CelotexCorporation, et al, ) ) ) Defendants. ) _______________ ) ANSWERS TO INTERROGATORIES Carey Canada Inc., for answers to interrogatories and response to request for production, states as follows: 1. Give the full current name of your company, its state of incorporation (if a corporation), the full street address of its principal place of business, its agent for service of process in the State of North Dakota (other than the Secretary of State), and state whether your company is registered to do business in the State of Minnesota. Answer; Carey Canada Inc. was incorporated in Quebec, Canada, in 1955; however, it did not begin operation of its mining facility until 1958. Defendant's address is Post Office Box 190, East Broughton Station, Quebec, Canada. There are no other places of business. Defen dant has never been authorized to do business in the State of North Dakota and does not maintain a registered agent in North Dakota. Defendant sells its fiber F.O.B. Quebec, Canada, and, therefore, does not conduct business in the United States. 2. If you claim insufficiency of service of process and/or lack of personal or subject matter jurisdiction as a defense to all or any part of this action, state all facts in support of such defense or defenses. Answer: As discovery is still continuing in this case. Defendant is not presently able to state the requested information. Defendant intents to assert any and all defenses properly raised in the pleadings. 3. Identify all companies (defunct or extant) which are or were related to you in any way (for example, as parent, subsidiary, predecessor-in-interest, successorin-interest, surviving or non-surviving company in a merger, etc.) and which at any time mined, milled, manufactured, sold or distributed asbestos or products containing asbestos, and state in full detail the cor porate history of those companies, including their corporate relationships with each other. (In this context the word "corpo rate" should be understood to include any form of business entity, not only business entities technically formed as corporations.) Answer: In 1958 Defendant began operating as a wholly-owned subsidiary of Philip Carey Manufacturing Company under the name Carey-Canadian Mines, Ltd. As of June 1, 1979, the corporation has been known as Carey Canada Inc. Carey Canada Inc. is a wholly-owned subsidiary of The Celotex Corporation. 4. State fully all information available to you concerning your direct or indirect sale or distribution of asbestos products to or in Minnesota and North Dakota including identity of products; identity of purchasers, franchisees and distributees; and dates and quantities of delivery. Answer: Defendant has never manufactured any finished asbestoscontaining products. It has only been involved in the mining and milling of raw chrysotile asbestos fiber. The majority of its fiber is medium to short in length and grayish white in appearance. -2- 5. If you deny that your company named as defendant in this action can be-held liable for plaintiff's exposure to the asbestos products of one or more of your related companies identi fied in your Answer to Interrogatory Number 3 above, state all facts in support of such denial. Answer: As discovery is still' continuing in this case. Defendant is unable to state the requested information at the present time. However, Defendant intends to assert any and all defenses properly raised in the pleadings. 6. For each asbestos containing product manufactured and/or distributed by you state the following: (a) The brand name of the product; (b) The inclusive years of manufacture and/or distri bution; (c) The type of asbestos fiber used in each product and the content by weight for each product for each year manufac tured; ' (d) The dates on which caution labels were first placed on each of the asbestos containing products and the date of first shipment of such products with the caution label thereon; (e) The actual wording of the caution label with a representative size thereof on each product by year; (f) Whether any such product was labeled with the name " of a company other than yourself and if so, for what years and under what name to reflect that they were manufactured or distrib uted by another entity; -3- (b) Name and last known address of person with disease, if other than claimant; , (c) Date and manner of first notification of claim; ' (d) Nature of disease alleged; (e) Manner of exposure (e.g. insulation worker, factory worker, etc.) and number of years exposure; (f) Full case titles and file number if a formal proceeding of any type was commenced; (g) Name and last known address of claimant's attorney; (h) Resolution of claim (settlement or verdict; amount paid, if any). Answer; Defendant objects to answering this Interrogatory, as any workman's compensation claims made by employees at Defendant's mines, where workers are exposed to 100% raw asbestos fiber, is irrelevant to the issues of this lawsuit, nor is it reasonably calculated to lead to the discovery of admissible evidence. 28. If you have ever taken any measures (such as warnings, cautions, provision of masks or respirators, enhancement or ventilation, x-ray or other physical examination, etc.) to reduce asbestos disease and exposure to asbestos among your employees in mining, milling, manufacturing, selling or distributing, state in detail what measures were taken, where they were taken, when they were taken, who recommended or suggested that they be taken,* and who ordered that they be taken. Answer: Defendant objects to this Interrogatory, as the working (and environmental) conditions at Defendant's mine, where workers were exposed to 100% raw asbestos fibers, has no relevance with respect to insulators or others who were exposed to asbestos-containing products (wherein -10- asbestos was encapsulated in a finished product and typically, such industrial products contained 15% or less asbestos fiber). In an attempt to be responsive and without waiving its objection. Defendant states that since the early 1960's, certain employees in dusty areas have been required to wear respirators. Respirators are worn by the driver of the bulldozer and by employees who have occasion to work in the area where the tailings are dumped or in the dry rock storage area. Defendant uses respirators approved by the Provincial Government for pneumoconiosis-producing dust at its mining operation in East Broughton, Quebec, Canada. Prior to 1974, Defendant used the Willson & Dustfoe respirators. In 1974 Defendant purchased the 8710-3M respirators from Lynn MacLeod Engineering-Arkon, Inc., and in 1975 the Air Stream Helmet System from Desco Inc. In 1976 Defendant purchased the 800-248-00 respirator and White Cap Helmet System from Safety Supply Company. According to the best scientific and medical information available. Defendant believes that regular use of such protective devices will prevent the development of asbestos-related diseases in those persons exposed to asbestos. Furthermore, Defendant states that between 1959 and 1974, Defendant took dust counts with the "Midget Impinger." A description of this technique is attached, marked Exhibit B. During 1973 and 1974, dust counts were taken with the "Midget Impinger" and "Membrane Filter." Beginning in 1974, dust counts have been taken only with the "Membrane Filter", a procedure based on NIOSH: USPHS/NIOSH Membrane Filter Method for Evaluating Airborne Asbestos Fibres. Please contact NIOSH for a description of the procedure. Various studies have been conducted to determine proper ventilating systems at Defendant's facility. However, ventilating systems must be selected after a complete review and analysis of the specific location under consideration. Since the ventilating systems selected and installed at Defendant's facility bear no relevance to the working conditions of the Plaintiff involved in this lawsuit, Defendant raises objection to this Inter rogatory and declines to answer further. . -11- In addition, workers were periodically sent safety bulletins prepared by Quebec Asbestos Mining Association (QAMA), such as those marked Exhibit C, regarding the suspected hazards of asbestos exposure. The exact dates of distribution are unknown, and further inquiry should be directed towards QAMA. Chest x-rays have been provided as part of the pre employment physical given to new employees since 1958. Annual chest x-rays have also been given to employees since 1958. 29. If any employee in your mining, milling, manufacturing, contracting, selling or distributing operations has ever been diagnosed by any physician as having asbestosis or any cancer related to asbestos exposure, the name, address, date of diagnosis, and general circumstances of exposure as to any person so diagnosed before you ceased (if you have) sale or distribution of asbestos products in Minnesota and North Dakota. Answer: Refer to Response No. 27 above. 30. If you have ever conducted, funded, commissioned, requested, or in any way participated in any studies, tests, research, experiments, or the like, concerning the health effects of inhalation of asbestos fibers, set forth all dates, organiza tions and persons involved, sources of funds, results and related publications. Answer: Defendant has not directly conducted any study concern ing asbestos and its relationship to health and safety concerns. However, as a member of the.Quebec Asbestos Mining Association (QAMA), Defendant has been indirectly involved in efforts of this nature. The Association should be contacted for specific information concerning these studies. Carey Canada Inc. does not have copies of the reports for the various studies undertaken by QAMA and its suborganizations. ' -12- 31. .If you know of any tests, studies, research or experi ments concerning the effects of inhalation of asbestos fibers, conducted at any time since 1900 by any member of the asbestos products industry (miners, millers, manufacturers, sellers, etc.) or by any group or organization of or related to that industry, give the titles, dates, participating company(s) or organizations) and responsible individuals. Answer; Refer to Response No. 30 above. 32. State the names of all industry or trade association periodicals to which you subscribed, or which you received without subscription, at any time from 1928 to the present, giving the period of subscription or receipt of each. Answer: Defendant has been a member of Quebec Asbestos Mining Association (QAMA) since 1958. Defendant has received various publications since 1958, but has no records reflecting exactly which publications were received or when they were received. Defendant has also received Asbestos magazine since 1958. 33. Identify by name and date all medical texts, treatises, journals, studies or reports, whether privately or publicly circulated, which you received or obtained at any time from 1900 to the present and which concerned in any way lung disease or occupational health subjects. Answer: Defendant objects to this Interrogatory as unduly burdensome and irrelevant insofar as it refers or relates to listing, describing or indexing medical literature and other documents relating to the asbestos litigation. These documents were recently gathered in anticipation of, or during, litigation. These documents do not, therefore, represent Defendant's or predecessors' knowledge of the contents of the documents at' or near the document's alleged publication date. -13- 34. Give the names and last known home and business addresses of all physicians who were employed, contracted, or otherwise engaged by you at any time from 1900 to the present, and give the dates and purposes for which each such physician was engaged. Answer: None; however, any employee experiencing any pulmonary problems was referred to the L'Institute de la Medicine Industriel de Thetford. Dr. Richard Lambert is in charge of the Institute. The Institute is funded by Defendant and other asbestos producers. The cost of hospital care is underwritten by the Quebec Government through the Province-wide Medicare Plan. 35. Give the names and last known business and home addresses of all persons employed, contracted, or otherwise engaged by you, as an industrial hygienist at any time from 1900 to the present, giving dates and purposes for which each such person was engaged. (For purposes of this Interrogatory, an industrial hygienist is one who performs engineering or.health studies or other services to identify, evaluate or attempt to eliminate potential occupational health hazards.) ' Answer: Defendant objects to this Interrogatory on the grounds that any report from an industrial hygienist studying mining employees* exposure to 100% raw chrysotile asbestos fiber is not relevant to an insulator's or bystander's exposure to asbestos products. 36. If you have ever been a member of the Asbestos Textile Institute, the National Mineral Wool Association, or the Asbestos Cement Products Group, state the years of membership; identify all meetings or conferences attended; and identify by date and title all publications received which related in any way to the dangers of asbestos exposure. Answer: No. -14- 37. .If you were a member of the Air Hygiene Committee of the Asbestos Textile Institute, state when and identify all meetings of that committee attended by your representative. Answer: Not applicable. 38. If you have ever been a member of the Industrial Health Foundation, give the years of membership, identify by names and current addresses any of your employees or representatives who were present at the 20th annual meeting of that organization in Pittsburgh, Pennsylvania, in November of 1955, and state whether you received that organization's monthly publication known as the Industrial Hygiene Digest. Answer: No. 39. State whether the defendant ever requested officials at the IHF to: . (a) Perform a search of the medical literature to determine whether any scientists or doctors were reporting cases of insulation workers with asbestosis and/or cancer or discussing the potential hazards incident to use of asbestos containing insulation products. (b) Perform any studies or research into potential health hazards incident to the use of asbestos containing insula tion products. ' (c) Review governmental publications of Great Britain toward the end of determining whether any research was being conducted by the British Government into any potential health -15- hazards incident to the use of insulation products containing asbestos. . (d) Review governmental publications of Great Britain to determine whether the Chief Inspector of Factories or any other British Government agency had issued any regulations or published any findings relative to potential health hazards incident to the use of insulation products containing asbestos. Answer: No. 40. If you have ever been an associate or correspondent of the Asbestos Research Council of England, list meetings attended and identify by dates and titles and other pertinent identifying information all correspondence or publications sent to that organization or received from it. ' Answer: No. 41. For all insurance companies which carried your Workers Compensation coverage at any time from 1900 to the present, give name, address and dates of coverage. . Answer: Defendant is a Canadian corporation, and workman's compensation insurance is provided by the Quebec Govern ment. 42. If you deny that plaintiff has (or that plaintiff's decedent had) a disease caused entirely or in substantial part by asbestos exposure, set forth in detail all information in support of your contention. Answer: Refer to Response No. 14 above. 43. Identify by date, author, recipient and subject all documents obtained by you or any other defendant from Asbestos Workers Local which you claim support any of the defenses asserted in your Answer. . Answer: As discovery is still continuing in this case. Defendant is unable to state the requested information at this time. 44. Identify by names, addresses, titles, positions and functions all persons who have participated in preparing Answers to these Interrogatories. Answer: It is impossible for Defendant to respond to this Interrogatory with specificity, as various persons from many departments were consulted in answering these Interrogatories. The Responses to these Interrogatories are prepared by the Legal Department of the parent corporation of Carey : Canada Inc. They are signed by Robert W. Emerton, III, Senior Litigation Counsel, as authorized representative of the corporation and not on the basis of his personal knowledge of the facts stated herein. 45. If, in answering these Interrogatories, you have not reviewed any documents in your possession, custody, or control, which might contain information sought by these Interrogatories, specifically identify those documents, their location, and their custodian, and state why you did not review them. Answer: Not applicable. -17- - RESPONSE OF CAREY CANADA INC. TO REQUESTS FOR PRODUCTION OF DOCUMENTS 1. Produce copies of all documents containing any of the information sought by the above Interrogatories, separately identifying each of those documents by the number(s) of the Interrogatory(s) to which it pertains. Answer: Refer to Exhibits A through C in Response to Plaintiff's Interrogatories. 18- The undersigned, ROBERT W. EMERTON, III is Senior Litigation Counsel for the parent corporation of Carey Canada, Inc., East Broughton Station, Quebec, Canada G0N-1H0, and signs these Answers to Interrogatories as such. However, he has no personal knowledge of the facts as set forth herein. And further, such facts are the result of'the investigation by attorneys on behalf of Carey Canada Inc. and he affirms these Answers for purposes of taking necessary official action by Carey Canada Inc. only. I l a) Robert W. Emerton, III CAREY CANADA INC. Senior Litigation Counsel STATE OF FLORIDA . COUNTY OF HILLSBOROUGH Before me the undersigned, a Notary Public in and for the County aforesaid, this day appeared Robert W. Emerton, III, who stated he is authorized to execute the foregoing Answers to Interrogatories on behalf of Carey Canada Inc., and that the matters stated in said Answers are true and correct to the best of his knowledge, information and belief. SUBSCRIBED AND SWORN TO BEFORE ME, this day of MuV.UU.TM-, s Notary Public in and for State of Florida County of Hillsborough \ Notary Public State of Florida at un,t iJty Commission Expires Au. 15,19d5. The undersigned, ROBERT W. EMERTON, III is Senior Litigation Counsel for the parent corporation of Carey Canada Inc., East Broughton Station, Quebec, Canada G0N-1H0, and signs these Requests for Production as such. However, he has no personal knowledge of the facts as set forth herein. And further, such facts are the result of the investigation by attorneys on behalf of Carey Canada Inc. and he affirms these Answers to Requests for purposes of taking necessary official action by Carey Canada Inc. only. CAREY CANADA INC. Senior Litigation Counsel STATE OF FLORIDA COUNTY OF HILLSBOROUGH Before me the undersigned, a Notary Public in and for the County aforesaid, this day appeared Robert W. Emerton, III, who stated he is authorized to execute the foregoing Answer to Requests for Production on behalf of Carey Canada Inc., and that the matters stated in said Answers are true and correct to the best of his knowledge, information and belief. Notary Public in and for SSSx&&aa.tte ooff FFlloorriiddaa Notafy Public State of Florida at Lar^s County of Hillsborough * My Commission Expires Aug. 16,1985,; The Insurers covering Carey-Canadian. Mines, vith policy numbers and terra of coverage, arc: Insurer Policy No. Team Aetna life & Casualty CNA/Assuranee II II . If It u it it it It It 11 It Lumbermen's Mutual it tt Employers of Wausau General Accident It II it it 985 LG-305S4SCA CCP 248-3280 CC1> 248-3414 834-0276 822-5714 822-5714 822-4673 822-3476 OYL 295175 9YL 295175- 27904021047 GIA .36-748-15 ICG 427410 All Prior Coverage 11/15/76 - 10/1/77 10/1/76 11/15/76 10/1/75 10/1/76 10/1/74 10/1/75 10/1/73 10/1/74 10/1/72 10/1/73 4/18/72 10/1/72 1/1/71 - 4/18/72 i/1/70 - 1/1/71 1/1/69 - 1/1/70 1/1/68 - 1/1/69 1/1/67 - 1/1/68 1/1/64 - 1/1/67 Foreword. * - Those who v/ill encage in dust sampling end counting will " find the various techniques .much easier to understand if they realize at the outset that we have no absolute or precise method of deter- . mining the total number of particles in a given sample of air. Most of the sampling methods do not collect all of the particles and if they did, all of the particles could not be-counted by any known method. (The electric precipitator, which will be shortly.discussed in another article, has, for all practical purposes, a collection efficiency of 100 per cent}. . .. Iri making dust counts, -the most important consideration is that the method should yield results which can t-e compared with, those obtained by other workers, under similar conditions. That is to say, it should give the same results (within about 10 per cant) for different operators sampling the same concentrations of a given dust so that the conditions as found can be compared with similar con ditions where observations over a longer period cf time have per mitted an evaluation of the hazards involved by a continuation of engineering and medical -studies. ` . * . THE IKPIEOSR. .. . .. . The word "impinge-"' means to strike or dash against. In the' impinger method of dust collection, the sample of..air is sicked tor drawn into, a nozzle shaped tube and on into the flask at high velocity. The flask .is partially filled with a liquid and as the dust, particles strike against a plate or the bottom of the fjusk; they- are wetted and retainsu in the' liquid while the air bubbles 'through the liquid and escapes. '_ '' ' Hie Sruenburg-Smith. or large Tmpinger was developed during a study of available dust sampling devices started in IS1*? at the Pittsburgh 3ursau cf Mines Experiment Station (1) b (2). As finally adopted, the Impingar sampled at a rate of 1 pu. ft. per minute into a flask 50 mm. in diameter and 300 mm. in length. The source of suction was either a motor driven pump, an air ejector, or a rather heavy find bulky hand-operated pump mounted on a tripod stand. This impir.gor was found to meet the requirements for a dust semniing method more satisfactorily than the other methods studied and with light-field counting, in the microscopej comparable results could bq obtained by different workers. :: .'  Distilled .water was first used as the collecting mediae but alcohol has been used recently because most inorganic dusts-* less soluble in alcohol, some dusts us coal are wet by the olccnS. .. m<?re readily, there is' no trouble from bactei'ia and mold confusr?-. the counting, and the apparatus is more easily cleaned with alccsSl Alcohol has also been found more desirable for sampling whore tbe air is contaminated with oil mist as in rock drilling as the. oils soluble and does not agglomerate the dust or-otherwise confuse tis. count. Ethyl Alcohol is satisfactory but, is very expensive tecsse 'of high taxes so either normal-propyl or iso-propyl alcohol has has. substituted; normal-propyl being more desirable because of the oik-. jectionabla odor of iso-propyl alcohol. .. ' .. THE MIDGET IMPINGER. * ' . The USA Midget Impinger is, as its name implies, similar in principle to the Oreonburg-Smith or large impinger, but is smsusm in size and collects a smaller sample, The Midget Impinger was d'eveloped at the Bureau of Mines (3) & (4). * . The USA Midget Impinger apparatus consists of a case wir . a four cylinder radial pump using the crank case as a surge tank. " Each stroke of a piston pushes air from the crank case, maintains a vacuum reflating chamber which maintains a constant vacuum on tie impinger to which it is connected by a short hese. Any crank spead above about 50 R.P.U. gives a constant flow. A nut on the baek'cf ' the regulator varies the tension of a spring which maintains the correct vacuum, and a gouge on top of the case indicates the in inches of water. The entire apparatus with nine complete impingers (flask and nozzle only complete with stoppers) in a removable block, an inlet guard, holster and carrying straps waigpa- but nine pounds. ' Dust Sampling with the MSA Midget Impinger. ** . "Cleaning, the Apparatus- . . . ' * .. Vn* ' . . A most important part of any dust sampling technique is-a . thorough cleansing of the apparatus. The 1.beratory room used for 'this.preparation should be kept, clean and.free of dust and a large glass plate should be provided on'a bench next to the sink, and should be polished each time it is used as a work piece. The impingers (see figs. 1 t 3 in El 3360) are removed from the block, one at a time, and the cap, side arm stopper and largo stopper am? removed. Each part is rinsed in water, scrubbed with'a brush ushg a detergent such as ''Draft" which does not form precipitates with hard water, rinsed with warn water, then with distilled water* and finally with dust-frae alcohol. The flask should be filled with .about S ml. of the alcohol, then the large Stopper and nozzlo * washed and put into the flask-and the end of the nozzle adjusted ts. the 5 mm. mark. Then the cap, and finally.-the side .arm storjper mr put in place. The flask is dried on the outside and a strip of ^friction tape or cellulose scotch taps is.placed over the joint . between the largo stopper und the flask. ~ Checking the apparatus . ' ' -| * . ' Unwind the hose from the spool on the back of the regpatr bring it thru the slot at the end of the case and connect the * end to the side arm of an impinger flask-containing about 8 ml. alcohol. Remove the cap on the impinger nozzle and.stand the impinger in the block which is removed from the case. Turn the air- fast enough to hold the gauge needle steady (about 50 r.p.m.) . note whether the vacuum reading is 12 inches of water. If it isSt. tighten the nut which is at the back of the regulator on the pnmj- if it is too high* loosen the nut until the needle holds steady^ ' 12. If it is desired to check the flow thru the impinger* the apparatus should be set up as described and the inlet (top) con nection of the nozzle connected to the outlet of a small wet meter : (0.1 cu. ft. per revolution) and the time. for * several revolutions':. . the meter pointer is measured with a stopwatch. . 1 ? 5 ; ; !' : ; Collection o Samples: . The parts are placed in the case and the apparatus is oestready for collection of samples. The case is worn-at the left 23?' with the strap over the right shoulder and the crank away from fir . body. When it is desired to operate the .apparatus > the left ar^ar drawn through the loop of ,the strap and the csss is rotated lS-T clockwise so- that the end farthest from the gauge is against end the crank is in a position for .operation with the right hand- . Open the case* unwind the hose and remove an impinger.Se move the cap and side arm stopper and .connect the hose to the sis-- arm (wetting the end with saliva if necessary). , The impinger rsrps- held in the left hand which also. supports the far end of the csss. If a stand or table is convenient* the block can be removed fresfit `case and placed up >n the stand with the flask in it. If a sstaple" required near a workman's face to determine, bis exposure* the nsa&' con be put in the holster and pinned to his jacket with the hose--_ brought over his shoulder to the apparatus.. Wherever there is 2* " possibility of material dropping from overhead* th9 inlet of ths flask should be protected with the Z-shaped guard. \ [ ' ; The crank cf the pump is turned (either \ra-j) for the r.r I i1 ' ling period at sufficient speed (50 or more rcvolutic-s per minnsp. to keep the gauge at 12 inches of. water. * The sampling period shfiS be 10 or more minutes in length for concentrations which are ezasE- to be 10 million particles .par cubic foot and five minutes for f1 concentrations. Where only one or two million particles per ctssr foot-is expected* the sampling- time should be 15 or 20 minutes. A soor* as the sample is collected* the hose should be removed endfi \ cap and side arm -stopper replaced.- The flask should be numbered with o gloss marking crayon so that the results can be correlate, with notes describing the location and -conditions. ' Determination of Count. (5) ' . . The samples are returned to the' laboratory where th r%- ere thoroughly washed on the outside before the tape and stopjex ere removed. Always remove the side-arm stopper first or presses built up by increased temperature msy force some of the sample of the intake tube. Then wash the inside and outside- of the iosssr tube (the intake to the nozzle), using a wash bottle with dust-hs .alcohol and making sure all the washings go into the flask. Ties add alcohol until the volume in the flask (with the nozzle removal is 20', 25* or 3 ml; the lower volumes only- for very low counts. The flask is then a coppered with the large stoppers with nozzle* ' the cap, and lastly the side-arm stopper,.or a solid stopper momis used in place of the one with the nozzle. The stops to be followE,'. after the sample is collected and prepared as described above will `be listed briefly. ` . .* The sample is counted in a Sedgwick-Rafter cell which * be made with a. cement insoluble in alcohol. This cell is glass, 1 mm. deep and with a capacity of about 1 ml. (the volume is un important) . The cell is rinsed with alcohol after use and kept xct?- its cover glass in a beaker of .clean alcohol. About 6 cells can ss~ `kept in a 250 ml. beaker.- When' needed, a cell is removed and dr-isr with linen or silk which is clean and free, of lint. It is then brushed out with a clean camel-hair brush and the cover glass whies is m3de from a- standard clean microscopic slide by cutting down to .2-3/8" length is cleaned' similarly and placed upon it so that two corners are open about l/4".t; ' . The sample is shaken thoroughly and a clean 2 ml. pipetfc is filled quickly with it and emptied again into the flask. The stopper is replaced and the flask is again shaken well after uhica the pipette is again filled and .the sample is run into one of the - open corners of the cell until it is filled; the fluid remaining 5n the pipette is desesrded and. the cell is closed. Be sure the - pipette is not placed on a dirty surface in this procedure and ** generally avoid contamination of the sample.* The sample in the cell is allowed to 3tand on a flat sur face for 25 minutes, after which it is placed upon the microscope stage end five fields of 1/4 sq. millimeters each are counted, ccnsfe- ingtbe particles on the bottom of the cell in this area. ' .' ** *. * ' ' .The microscope for counting should have a magnifies tionxfT ebout 100 diameters using a 10 x objective and a 10 x eyepiece. 3. the eyepiece there is a Whipple Disc which is a' glass disc upon is marked off a square subdivided into 100 small squares, one of which 13 again divided into 25 smaller squares. The draw tube sbnffi. be adjusted so that thi3 large square includes an area 1 nrn x 1 n at the point of focus on the stage; a stage micrometer is used to get this adjustment. (The miscroscipes supplied by the MSA Co. sss. properly adjusted at the factory.) .. ' - J+ : The-light is placed about 8 ittShe3 from she mirsar ' end the.iris diaphragm is closed to a small aperture and tie- eyepiece is removed. Then the mirror (plane surface) is ts-, until the spot of light is centered in the microscope tuie. (with the eye directly above it). T! e eyepiece is replaces and the bottom of the cell is found by focusing on a corns- where a large amount of dirt, inevitabl present, helps last: the surface upon which the dust has settled. New one of tie five fields is selected, at least 3/8 inch from an edge cr2r a bubble which may get in the cell, and using the fine adJsaEfe. * the particles to be counted are brought into focus. At this pqint. it is desirable to lower the condenser (beneath the - stage) and adjust the iris diaphragm for a comfortable liga. intensity (too much light is very tiring on the eyes). CosaC with both eyes open, using a dark cardboard shield around fis- eyepiece and keeping the room slightly darkened. - j . Each field should include 1/4 of the large squares- t 25 of the first subdivisions and while counting the fine ad- - ! Justment should be turned back and forth as only the partidile . f which go an and out of' focus are cotinted to exclude any par=.- : cles which may be on the/.-/hippie disc. The five fields mays*- ' ' counted in five minutes so cells can be filled on a 6 - 1C f minute schedule. A hand tally is helpful in making the corns: ? and the eye should follow a regular ' course so that the posit is not lost. Some whipple disco., as modified by Page haves. . a 1/4 square millimeter, marked off> so in this case the whose 'area is counted. ' . : ) .* t Each.day one c-r more blanks should be counted, us^u. : the alcohol provided for sampling and diluting. This blank should not exceed an average of 7 or 8 particles per field as' .' is subtracted frum the counts found. The alcohol reservoir... . should not be disturbed and is best provided with a glass sat. at least one inch above the bottom. The siphon should end 5sv- * , a piece of clean gum rubber tubing with a glass nozzle and a l spring clamp c-n the rubber tube for opening and closing. -= . * When the Whipple disc becomes dirty, it should be i 1 cleane-d with several thicknesses of lens paper and brushed with a camel-hair brush. Never touch the surfaces with the _ ; hands ox* trie surface of the'lens paper used for wiping. Oil ' from the skin makes streaks, and helps the dirt to stick. Aleg- handle the disc by the edge and replace it with the sane ~ >' surface uo. ' ' "i ' Sample Calculation: ' * . * i .. ' Suppose we' collect a 10-minute samole of 0.1 cu. per minute, dilute to 30 ml, and get counts of 47, 49, 50 ad 48 for one cell; 46, 50,51,45, and 44-for a second cell, asx have a blank count of 5 per field. We average the counts: - 1 j* L*1 6 * 47 49 ... 45 ' 50 . jLi. '46' . 50 51 . .45 44 " - 5) 233 (48) 5)' 236 (47) ^ ` Av. - 48 -- blank of 5 - 43 43 x 4 = 172 particles per eu. rcillimetee. .. ' 172 x 1000 = 172,000 per milliliter ' 172,000 x 30 = 5*160,000 total particles . in sample collected. ' . . Sampling period was 10 min. at .1 ru. ft. perm ' or 1 cu. ft. of air was sampled so dust conces` tration is 5*2 million per cu- ft. ' ' (Usually the amount after the decimal is not significant). . . ` More simply the calculation is: _ 43 x 4 x loop x 30 * ' ' . 5.2 million per cu.3, lx 1,000,000 ..... _ *t In general, .the count per field should be 40 to St particles where it is much above this, part of the samcle,3ar; 10 ml. should be further diluted in a 23, or 100 ml. voliaaS. flask. . * . (1) U. S. Public Health Bulletin #144, "Comparative Tests2? Instruments for the Determination of Atmospheric DustJij. 'S. K. Katz, C. VJ. Smith, Wm. Myers., L. J. Trostel, Maggpt Ingels, Leonard Sreenburg Jan. 1325* . (2) U. S'. Public Health Bulletin-#217, "The DeterminationaB''- . Control of Industrial. Dusts", J. J. Bloomfield, & J. 5. ' Delavaile, April 1935- ,. .* . (3) Dept of the Interior, Bureau of Mines Report of IvvesJasb.. 33o0, "Bureau of Hines Midget Impinger for Dust Sample by J. B. Littlefield and K. H. Schrcnk, December 1937. (4} Dept, of the Interior, Bureau of Mines Report of Invest . .gdtions 3387, "Dust Samoling with the- Bureau of Mines2S- ImpSnger, using a new Hand - Operated Pump" by J. B. Littlefield and K. H. Schrenky March 1938. - (5) The technique- Tor making dust counts is best desorttsSfe Tept. of the interior. Bureau of Mines Information Car. 702o "A Technique for use of the Impinger Method" bgr Carlton 3. Brown and H. H. Schrenlc, June 1933. (6) This equipment is described in Bureau of Mines 1. Cf3E' referred to `abL.ve and in Bureau of Mines R. I. 3373, "Microprejec tion Method for counting Impinger Dust Sample? :by Carlton 3. Brown, Lester A. H. Burem, William P. Yant,a&H. H. Schrenlc, Jan: 1933. rt i CAREY CANADA INC ^. ~ 25/XI/81 by: J. Sztdbe ASBESTOS DUST CONTROL .. at QUEBEC ASBESTOS CORP. and Carey Canadian Mines Ltd ** CAREY CANADA INC. DATE 1952 - 1956 1959-VI to 197A-V 12/11/73 PROCEDURE at Q.A.C. UNITS Midget Impinger { MPPCF (a) see enclosure (1)! and (2) -------------- ---------------------p at CCM Ltd = C.C.I. Midget Impinger MPPCF (a) MEMBRANE FILTER (b) f/cc PERFORMED bv: t QAMA - M. Lachance -W do do 29/XI/73 ' to Midget Imp. MEMBRANE FILTER MPPCF f/cc .. do CCM - R. Shearer 9/1/74 to ' 6/V/7A 1974 to 1976 30/IV/76 1976 - on Midget Imp. MEMBRANE FILTER MPPCF f/cc Midget Imp. MPPCF MEMBRANE FILTER I f/cc -about 226 tests performed. Quebec Dept of Nat. Resources - G. Gabaas;. CCM - R. Shearer -------------------------------- 3# QAMA - M. Lachance Hi ICCI MT 1st half yearly (l/XI/75 - 30/1V/76) - AIR SAMPLING presented to Que.- Gov. Authorities MEMBRANE FILTER ! f/cc : CCM Ltd. MEMBRANE FILTER ' f/cc I CCI Half yearly reports covering* the.-whole MINE, plus MILL sampling at bi-monthly intervals, plus testing of problem areas and jobs when needed. c, m& sf A' NOTE: (a) MPPCF ---million of particles per cu.ft. (b) MEMBRANE FILTER, a procedure based on NIOSH: USPHS/NIOSIl MEMBRANE FILTER METHOD for EVALUATING AIRBORNE ASBESTOS FIBRES. . ' UNITS:. ` f/cc - FIBRES LONGER than 5 microns per cc.. Enel. 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'Asbestos gamii.txal fibre; a hydrated ;.': Vj^-Vt^iJtaasneiiutn silicate.There are several d : 'varieties of asbestos. Of these, commercially i . . {: the most valuable one is chrysotile. The worlt i` Y^Cjy-three leading producers of chrysotile asbestos r Canada. Ute USSR and Southem-Africa.: TOfthe 4.5 million tons mined tn.the world each. 1 -s w.. uw,,,uCncc or. - -i ' ^.-Sri^hkiard to the general public from the minute 'y T:;| ;_wij .-;s>-'rti(..:amountsof asbestos that may be present in ' \y -*| J. : '"J. .j Hardly any.--tr sYudy.b'y'the U.S. Public^.. '.'7; Service shows that only a 1iriy.fracn0n\:rj \\t ___-. ___ _^it r_ .;** j.';-^V--Jf'S;"/"-?-\v'* 7- 'c'v'*''*r~' ; -- long-term medical studies of workers who r^?;.yi?/are'exposed to asbestos in their jobs show that:,' !~Sf Becauseof the long latent perioibf asbestos- '..^frVJ^^'felateci dls'eases', some cases still occur among "^''A-w' fong-s'eryiceemployees whose exposures began ' a' time,when little was known, of the amount ''i/Zofasbestos-a human could tolerate, and when ' ' Y-Y'/v^.'u; believe that thes'e'cases will decrease in the ` 1 ___ j ,,_i,,___ __ ____ , J:____ ___ - 1 t se serrdepuis une centime a ounces p; 'U'.-.matiriauxqui n'ont pasete mis alepreuve et done bn ne connait pas les etfets sur Iasants.,*::-j : Beaucoup. L'industrie canadienne del .l-'.J/.'a commandite au eours des annees- unesdes premieres etudes faites en du Nord sur !es maladies causees par ramiante..... . j ' Ces etudes ont fourni des renseignements qui . v; -..:.-ont etc a la base des programmes ue' _ IV '.' controle de I'environnemenl que I'industrie a 7.1 .-perrecttbnnes et etendus avec le temps. On a " ~ - consacre des millions de dollars a {`acquisition materiel et de techniques rafHr.es pour - proteeerles travailleursdes mines tTamiante- . . -rlruciirysoiile. des usines de broyage el des ' " ;_~I- -fabriques:de produits contenant de " Par l'emremise de Hnscitut de ."Travail et des Ambiances de Montreal, 'J7 Tlndustrial Hygiene Foundation a *etdc divers hopitaux et universites v parlour dans le monde. I'industrie continue __ ~7l ..I ^ . -. ~'~*i>~-Non;dej prelivements fatts dans la'ville do "'.. ! -'i^;..^'.:New Yorker dansd^autres regions-urbainesdesy.^. ` ."i^S^.Etats-Unis par tin sroupe.de chercheurs de ,,' 'Y*3?CiCi'H6pital Mount:Sinai de New-Ydrkrmohtrent ' i-.V-.-^'que les hiveaux.de pplluiioaso'ru de beaucoup' V: '.^'^.inferieurs aux'niveauxjuges inoffensifs pour.les**. -^r-'?. travailleurs'de rimiante. De plus; il a e(e'::;,,'.;:^::;.;-j : >1=.-.,'!- : lTM,Ve.'recemment;qUe de petites-quantttes'de_\"v:'i . ^ d'amiante pro'venant de sources naturetles,' . ircdmme la degradation des affleiiremerits, ;.vT'-ri^. ^ . JCse.'ust'enLprbbablemcncdanJ Patmosphere 'depuisjf:' ; y-:'h?.i<Tdei millions tTannecs-Ainsi, revolution du..;. ; ' `i5,;S?'^;fgenre:humain a sans doute pris place 'dans une t`~o ' ^.atmospherecoritenant.de Pamiante.-: v''*"'' ................ .. . . ,'on peut contrfiler de fa?on satisfaisante le 1 .f'A- peine. Une etude du Service "de la ..._... ... PubIique des Etats'-Unis demqntre'que lefaiti'..*^ >r';:*-:;vV'.r- niveau des concentrations dans ies chantiers et jdans les localitesl Du point de vue de la sante . .'i^osjd'appliquer les freins ne libere soussa forme ssf m : :'.-.^;..v''S;:-publiquer, ii n'existe done aucune raison pour -'r' '. .Olav'voriginale qu'une ihfime fraction'de I'amiante ' -vi^^&interdire Pemploi des produits continent de -r'.X-Sj^que contiennent les doublures de freins. Sous;-._V ^X'V.i'action de lachaleur. le reste se-.convertit en ^'I-t'Sforsterite. matiere non fibreuse,'inerteet- . $r<~ .m .'En verite, e'est a son detriment que la ^ tsepriveraitde la 3rar.de variete des produits de I'amiante servant i prpteger la. -. a ... : :s5^.T\inoffensivei} s!;i- :#6a 'sante,'la'vieet la propriete. ' I "J i ti.*-'-:a-; - ri '' -.m. `S}< . 2;"-Non. il n'existe aucune preuve,; ^'r-autre, que quiconque aitjamais contracte une* _ '. ".'SrX.maiadie pour avoir etc expose aux infimes. - 'v-'-i^quantites d'amiante qui se trouvent dans :. -y.yy: Patmosphere par suite de Pemploi. de Pusure- ' ;:4| ?r'-ou lie la degradation des produits de I'amiante.' .-' ........ ..... ue pertode de latence des - ' .'.`>j:.M?i"'aladies attribuables i I'amiante. bn voit . T-jg encore certains cas se diclarer ch des : , 4 ';:.':i'-;''P employes de vieille date ayant commence k '' . /' v.'.?*. j ' r'.T^'l^travailler 1 iine epoque ou Ton ignorait les _ & le.?--.!. ^-^.'concentrationssupportable* et ou le materiel j pour le controle des poussiires n'etait ni aussi ni aussi'repandu que maintenant. *'{. .:!m! medicates et l'amelioration des V. -l. 'jCJ de contrdle, on a toutes raisons de . ' . 'j-hj; <-: r.-,-. .. -J'.t.v.'croire que ces cas diminueront h I'avenir et que ' %: -^tje*maladiesreliees 1 i'amiantecesserontde. .. - * 7 '.e Non. des enquetes medicates Petat de sante des travailleurs ./Vt.Vr'pousjieres d'amiante montrcntque . . ' A~Vi'v concentrations peu elevees n'amenent aucune ' :'l '-'-/vV augmentation du taux des ` ' -iL'omfame esrrnie fibrtrnrinerale. tm silicate de-.. magnesium hydrates II existe plusieurs varietes-... ' d'amiame- parmiltesquclles la chrysotile est la - '.-. : `plus precietisedu pointde vue commercial; Les' . trois principaux pays producteurs d'amiante x.;.' '. chrysotile sonMe Canada, la Russie. I'Afrique _p '.du Sud et la Rhodesie; La.Russie est le . -principal producteur et leprincipal consom--. fmateur desiquatre-millionset demi de tonnes 7 d'amiante produites chaqueannee, tandis quede- . Canada est le principal exportateur et les 'Etata-Unis, leprincipal importateur. Le Canada - fournit 35 pour cent de.Ja production inondiale-7'. annuelle d'amiante. soit l.6 million de tonnes, i'apportanr ainsi i I'economie.canadienne presj7 ."'d'un quart de milliard de dollars par annee;,;v'. -Vdi-- \? permet de croirc pouri '~.;Aj-'>-Ti('que les infimes'quanu'tes d'amiante qui se.. . '.V* "` .'' .;''";-`: trouvent dans fair presentent un danger *' ,;-;v '^'-j quelconque pour la population'. DanJ une' . !1 v*-U1 Ii '-*<.:t ii:4c' !1<;!' <' = .. i i\-V- v't- *' \'5 'publication en'date d'octobre 1971 et intitulee.' ; jV.t ' ''Asbestos-- the Need for and Feasibility of . -'.':.rf;'r;/Air Pollution Controls. iL'amiante-- Necessite tyei. possibility d'un contrdiede la pollution - , '.v f I'.airmosnheriaue). 1'Aeademie nationals ( -.Presque tout lemOnde. H.esuimpossfbie de ' v*/ '.' conduire L'ii'vehicuIe,.depiloterun'r.2virirbu': un.avion qui'n'eh'comienne pas. On s'eirserr,;r..' ' pour les dou'olures de frein, les toiiures. ies. -systemes d'egouts. Ies carriages, I'isolation ' - J.. des installations electriques". les cloisons' '.[ '' ' icnifuges. lesrevetements exterieurs, les : veiements ignifuses. les lubrifiants et les -I-,-, -matieres pour le calfeutrage. I'asphalte des'Y--V.; - ' grandes routes, les fusees et les engins spatiaux, les carreaux acoustiques de mime que les . .turbines igazou i.vapeur et les-moteurs de fusee. Les gratte-ciel reposent sur des coussins en plomb et en amiante.Des tuyaux er.'charge .fails d'amiante-ciment transportent de I'eaii' . . fraiche. On trouve aussi de I'amiante chrysotile.. dar.s Ies immeubles prefabriques. les navires, les trains de metro, les avions et les sous-marins. II '..; .a licteraiement des douzaines d'applications au-' bureau. 1 I'lisine-. dans la maison de banlieue.-.-,," comme dans I'appaftement du centre-ville'. Sans amiame. le papier sur iequel est imprime .. _ ce feuillet n'aurait pu etre fabrique. Tous les v jours; on se sert d'amiante sous une forme ou.7"'i sous une autre.- .-.. ; T"*1 ina (jp. .. - **%**'!tfJ--J 71^i'w11.*' * * ;v K-.'-'i- '* quantile de fibres .que i'on trouve chez une - *V. grande partie de la population ait une influence :v:vV.d 7V.quetconquesur la-santeou Ixlongevite." .................................... .......... . -Ui" >; ' -i t -..j:3.5ri!- \ J r: i U; H I:; x1 :i U1. ........'............................ M :u 'M i-t-i- 11 V.srJ-. .; .1 .Hi*} Oui, on saildepuis plusieurs annees que ' ;i;.. certaines maladies respiratoires sont causees ;-'rV:';Par I'amiante.Cependant. on sailegalemenl . '''.V.--qua ces maladies n'apparaissent qu'apres une .- exposition prolongee a des quantiles excessives de poussiire d'amiante. Une etude receme faite '--'iJvpar 1'Universite McGill sur I'etat de sante de. . :10,42t mineurs ayant travaille et travaillant .I ;--";"T".;;j:.encore dans Ies-mines d'amiante du.Quebec 'v.monire que le taux de mortalite attribuable i :-:!!'"Ces maladies est inferieur au taux prevu pour ie .-.'.'I'.i'Jreste de la population quebecoise. Dans son ; '.r'v'. ..numero de juin 1971. la publication Archives of Environmental Health mentionne que la ;''"; y.:.-:;'mortalite est plus elevee dans le seul cas des ' . . Vlv;.'- travailleursqui. il y a30 ou 40 ans.ont ete ".-.":"r::';e.Tposes 1 de fortes concentrations de poussiere.. <. . ...; v- ;.. J Les fibres d'amiante s.ont uniques en leur ' 'I .1 genre. Combinees i d'autres materiaux--: et { I'amiante n'est jamais, ou rarement employ e seul -- eites donnent des substances ` .. '"j ,...j . ininflammables qui absorbent la chaleur causee par la friction, assurent I'isolation thermique et' ; i'insonorisation. renforcent les matieres .;. - | -I '! / S' e F fc It's an ASBESTOS world . Mora than 80 countries the world over buy Quebec's chrysotile asbestos. , They use these fibres to manufacture a range of some 3,000 products. These include: -- asbestos- . cement construction materials such as sheets and shingles, water and sewage piping: conduits, floor tiling, automotive brake linings and other friction materials; asbestos papers used in electrical insula tion and roofing materials; fireproof textiles, paints reinforced plastic products, asphalt overlays for highways, thermal and acoustical insulation materials and a range of gasketing, putties, caulks, sealants and surface coatings. You'll find Quebec's asbestos in Scandinavian homes. New Zealand high schools, Israeli irrigation projects; in the disc-brakes and clutch-linings of British racing cars, in a German welder's protective clothing, in the insulation of a Japanese turbo generator, in a Canadian paper machine ... It's in Brazilian housing projects, U.S. jumbo jets and gas stations, Indian pipelines and Central African locomotives... ITS PROPERTIES The worldwide acceptance of Quebec's chrysotile asbestos and its immense range c? applications stem from five inherent characteristics of the mineral: -- It is non-combustible, inert 2nd resistant to heat generated by friction. It insulates against heat, cold and noise. G Being a fibre that possesses greater tensile strength than steel, it acts ns a reinforcement . for many materials, especially cement and plastics. G It resists corrosion and attack by alkalis and most acids. It has good dielectric properties. What's more, chrysotile asbestos provides these characteristics, or any combination of them, at remarkably low cost. Because of this unique combination of properties -- not to be found in any other natural or man-made substance - chrysotile asbestos finds its way into hundreds of applications in which human safety is at . stake. .. It is indispensable in brake linings because it with stands the high temperatures attained in braking. Consequently road, rail and, to some extent, aircraft safety depend on it. It's the only mineral that can be spun and woven into'cloth for such uses as firefighters' clothing and fireproof theatre curtains. Used as a thermal insulation material on the structural steelwork of large buildings, chrysotile asbestos helps prevent them from collapsing in the event of major fire. And. It's also the basis of fire-resistant partitions in ships, offices, schools, hospitals, stores and other locations where large numbers of people congregate. In these and many other essential, life-saving uses, there is simply no known substitute for asbestos. ' Yet. for all its varied uses, Quebec's chrysotile asbestos is usually invisible in virtually all its applica tions. Like the yeast in bread, asbestos is just a small part of most finished products, yat it's indispensable. V J \ J The Mineral Like iron, copper, nickel or zinc, asbestos is a mineral. The chemical formula for chrysotile asbestos is 3MgO. 2SiOj. 2H,0. It is a hydrous magnesium silicate, closely allied to soapstone, the rock Eskimos use for their carvings. ` But unlike gold, copper, lead or zinc, asbestos is not an element and it occurs in several different varieties. In addition to chrysotile, there are types called amosite, anthophyllite and crocidolite. As well as being mined in Canada, the mineral is also produced in the USSR, southern Africa, Cyprus, Italy, the U.S.A., Australia, China, Japan and several other countries. Commercially, chrysotile is the most useful -- and valuable - form of the mineral. In Canada, it comes from Quebec, British Columbia, Yukon Territory, Newfoundland and Ontario. It is the only variety to be mined in Canada. ' Over 80 per cent of Canadian chrysotile produc tion -- or approximately 30 per cent of the world's supply of all forms of asbestos - comes from a 60- mile strip of Quebec's Eastern Townships between . the St. Francis and Chaudi&re Rivers. /------------------------ Its Production The rolling hills of Quebec's Eastern Townships have yielded chrysotile asbestos since 187S. Today, some 6,500 men mine and mill the tough but silky fibres. In the towns of Asbestos, Black Lake, East Broughton and Thetford Mines, five mining companies, created by Canadian, U.S. and British interests, produce more than 1,500,000 tons of chrysotile fibre a year. By doing so. they inject each year some $185,000,000 into the Quebec and Canadian economies. Mined in much the same way as other minerals, asbestos ore goes into a'mill, not a smelter. There it Is crushed and screened; the fibre is then separated, cleaned, graded and bagged ready for shipment to fabricating plants around the world. . Air is the muscle-power of this milling process. To separate a ton of fibre from the 20 tons of crushed mother-rock in which it is embedded requires roughly 10 tons of air in the form of suction. Vacuum is also the key to the complex and costly ventilating and dust control systems that protect the workers' health and the environment of the mining communities. .. A basic fact of life for Quebec's chrysotile pro ducers is that all chrysotile fibre is not the same. Some fibres are better suited than others for a specific manufacturing process. Because of the immense range of products that contain asbestos, Quebec's asbestos mines produce up to 150 different grades of fibre. Since the 1930's. grading procedures are uniform throughout the industry thanks to the Quebec Standard classifica- tion system for asbestos fibre. On the basis of fibre length, the Quebec Standard divides chrysotiie asbestos into eight basic groups which are further sub-divided into grades and sub-grades, determined by color, absorptivity, density, strength and other characteristics. These eight basic groups, which together with their grades and sub-grades make up the Quebec Standard classification system, are recognized the world over as a stamp of mineral integrity. J Each year, the Quebec asbestos mining industry pays its employees over S60,000.000 in wages and salaries as well as approximately S20 million in direct taxation to the Federal. Provincial and Muni cipal Governments. Recent Federal Government statistics reveal that the citizens of Asbestos and Thetford Mines are among the highest net income earners in the Province. ' Their incomes, plus those of hundreds of em ployees in the array of locally-established secon dary industries which supply much of the equip ment, supplies and services needed to keep the mines in operation, are the economic mainstay of the prosperous communities, with a combined total population of approximately 55,000, in which they live. Thanks to the overail prosperity which asbestos creates, the mining centres in the Eastern Town ships of Quebc contain cultural, educational and recreational amenities, ail of them citizen-run, which are second to none in Canada. ASBESTOS CREATES JOBS Approximately 6,500 men and women are employed in the mining and milling operations, maintenance shops and offices of Quebec's asbestos mines. Over the past 15 years, the industry's output has risen by over 50 per cent. This has resulted in a gradual increase in employment despite the closure of four mines in that period. The growing world demand for asbestos -- J r~. \ rising by an average rate of three to four per cent each year -- has led to the constant introduction of new more efficient mining and processing equip ment and control systems. - The result has been a shift in traditional employ ment patterns. Until some 15 years ago, well over half of a typical asbestos mine's work-force con sisted of production workers -- men engaged In the mining of ore and the milling of asbestos fibre. Today, that same proportion of workers is respon sible for maintaining in peak condition the produc tion equipment and process control installations that, ever-increasingly. are the muscle-power of the modern asbestos mine. - ' As well as providing steady employment for skilled production, maintenance and clerical work ers, the specialized needs and goals of Quebec's asbestos industry offer careers for engineers, accountants, research and industrial hygiene tech nicians, marketing specialists, traffic experts, security personnel, skilled craftsmen of all types, ventilation technicians, computer programmers, electronic repairmen and a host of other vocations. More than 95 per cent of all asbestos industry employees v/ere born, raised and educated in the mining communities themselves. . A measure of the stability of the employment offered by the industry is that, at one mining company at least, over 50 per cent of the em ployees have 25 years or more service. J r Asbestos Pay-Cheques Asbestos mining is a primary industry. As such, the mining companies must purchase from secondary manufacturers or suppliers the millions of dollarsworth of equipment, supplies and services needed to keep mines and mills in operation. There are consequently some 0.000 Canadians, the vast majority of them in Quebec, who benefit directly and indirectly from asbestos mining. These are just some of the secondary industries whose employees are paid, at least in part, by "asbestos pay-cheques'': -- transportation compa nies, machinery and equipment manufacturers, structural steel fabricators, automotive companies and truck-builders, electrical power distributors, oil refineries, explosives makers, paper and plastic container manufacturers, rubber companies, con struction firms, consulting engineers, diamond drill ing contractors, lumbermen and lawyers. The store rooms cf a typical asbestos mining company stock owe' 14,003 separate items -- from giant jaw-crusher components to carbon paper. Virtually all these items are manufactured in Canada. Whenever feasible, they are purchased from sup pliers in the asbestos communities themselves. Dozens of secondary industries in Quebec's asbestos towns depend on the mines for their business: -- foundries, armature rewinders, bag suppliers, trucking companies, industrial caterers, tire repair firms, steel fabricators, hardware sup pliers, building contractors. The total value of the equipment, supplies and services purchased by Quebec's asbestos mines is Jestimated to have increased from $3,000,000 in 1937 V r to over S42.000.0C0 in 1972. In recent years, continuing capital investment in the development of new mines and in the modernization and improvement of existing facilities has run as hioh as $100 million a year. Exploration expenses in Quebec during the 1957-1971 period amounted to S23.437.C00, while earnings reinvested in Quebec totalled 3107,955,000. V:J The World is our Market Place Per-capita consumption of asbestos in Canada is roughly comparable to that in the U.S. As a result, this country supports a small but vigorous asbestos products manufacturing industry, based mainly in the densely populated cities. And here there's a paradox. Even though asbestos fibre is ideally suited for themanufacture of con struction materials -- worldwide some 70 per cent of Canada s asbestos output is used for this purpose -- there's only a limited Canadian market for these products. . In a highly developed country like ours, asbestos- based construction materials must compete with a wide assortment of non-asbestos building materials, including brick, wood, steel, cemant, aluminum, plastics and even paper. The competition is chiefly based on delivered price at the building site. Although asbestos-cement is a high-qu3iity construction material, it contains comparatively little asbestos -- average 15 per cent. The rest consists of cement, a dense materia! which, in finished form, is uneconomical to transport over long distances. Moreover, the non-asbestos ingre dients are available at low cost virtually anywhere on earth. Because .of high transportation costs, asbestos- cement construction materials can only be eco nomically manufactured where the manufacturing plant is located close to the market it serves. These economic considerations, then, compel foreign manufacturers to purchase their fibre re quirements from Canadian asbestos mines, have them shipped to their plants and mixed there with J r -\ locally obtained cement. If, for any reason, the export from Canada of raw asbestos to overseas markets were to be restricted, and an attempt made to ship Canadian-made asbestos-cement products in its place, the high cost of importing these products would simply reduce the market for asbestos-cement materials in the countries where raw Canadian asbestos is now sold. For the Canadian asbestos industry, now exporting 95 per cent of its annual output, the consequences . in terms of production, sales and employment would be disastrous. , Canadian asbestos manufacturers can operate profitably in the export market, such as the U.S.. only by producing a limited range of items with a high asbestos fibre content. Current transportation economics, however, and the composition of asbestos-cement materials make it impossible for the Canadian asbestos products industry to export finished asbestos-cement products or other, materials with a relatively low asbestos content i J In recent years there has been growing public concern about the risks to health associated with asbestos. Quebec's asbestos industry has long shared this concern. It see__ .red in the 1930s some of the first studies in North America of ashestos-related disease. In the intervening years, it has expended millions ' upon millions of dollars on sophisticated equipment, .systems and techniques aimed at protecting the health of workers and of community residents by eliminating dust emissions both inside and from its mines and processing plants. Through the Institute of Occupational and Environ mental Health in Montreal, similar industrial health organizations and selected hospitals and universi ties around the world, the industry continues to SUpOOrt intpnciyo p-v*Hpraiotrin'i??3rV..irt res=rrh prolecis-- i nesc <*ie unsigned to ioerrmr nate asbestos-based health risks not solely for Quebec's asbestos production workers, but also for the worldwide fabricators and users of finished products containing asbestos. Scientific evidence amassed to date clearly indi catIets ttehhant:c--tnfi..nlla.l hpallh. riclfg flrp basiCSlIV Confined to the inh Rpttinn Fvprv cfpr is hpinr) taken to eliminate tnese neaitn risk?. 2) Asbestos-related diseases develop, generally, only after the inhalation of substantial quan tities of asbestos dust for a period of many years. 3) There is at present no evidence: That exposure to the minute amounts of J .. o ^ asbestos that may be present in community . air constitutes any hazard whatsoever to the general public. That any member of the public has ever contracted an asbestos-related disease as a result of the normal use of asbestoscontaining products, let alone of the oc cupation of building in which asbestos is incorporated. In view of the dose-response relationship that, according to scientific evidence to date, exists with asbestos-related disease, it now seems reasonable . to suppose that, by reducing the dose to which workers occupationally exposed to asbestos are subject, the current extension and improvement of dust control methods will lead to a reduction in the already low incidence of these rare diseases. In short, ail evidence indicates that the public is not at danger. The persons who may be exposed to risk - that is, the workers occupationally exposed to asbestos dust, now enjoy the protection of effectively controlled conditions, in the development of which the Canadian asbestos industry leads the world. (NOTE: With the aim of informing the public about the true facts relating to asbestos and the health risk, the Quebec Asbestos Information Service published in 1972 and reedited in 1974 a brochure entitled "Asbestos and Your Health". For a free copy, please write to the Quebec Asbestos Mining Association at the address shown. VJ Published by the Quebec Asbestos Mining Asso ciation on behalf of its member-companies: -- Asbestos Corporation Limited, Thetford Mines and Montreal, Que. Bell Asbestos Mines Ltd., Thetford Mines. Que. Canadian Johns-Manville Co. Limited, Asbestos, Que. Carey-Canadian Mines Ltd., East Broughton Station, Que. 'Lake Asbestos of Quebec, Limited, Black Lake, Que. Accurate and up-to-date information about Que bec's asbestos-mining industry is available from these companies or by contacting the offices of the Quebec Asbestos Mining Association at the follow ing addresses: -- Room 412, 5 Place Ville Marie, Montreal H3B 2G2 Telephone: (514) 873-3539 or. Room 320,580 Grande Allee East, Quebec G1R 2K2 Telephone: (418) 523-8168 LITHO IN CANADA E3M0774 J Dated this 19th day of March, 1982 GUNHUS, GRINNELL, JEFFRIES, KLINGER & SWENSON By __________________ , Richard N. Jeffries 512 Center Avenue, P. 0. Box 1077 Moorhead, MN 56560 Attorneys for Carey Canada, Inc. (218) 236-6462 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been mailed by first-class mail to all attorneys of record in this case on the 19th day of March, 1982. ' Richard N. Jeffries