Document Gm6nJYnzaOrMoj1GKvx9EeXX4

FILE NAME Johnson & Johnson JAJ DATE 1973 DOC JAJ222 DOCUMENT DESCRIPTION Senate Hearings for the Toxic Substances Control Act of 1973 CSPI comment BC Notes Center for Science in the Public Interest Oct. 4 1972 calls on government to revoke Generally Recognized As Safe status of talc largely because of asbestos pp 179-180 Barry Castleman Comments - Center for Science in the Public Interest Oct. 4 1972 calls on government to revoke Generally Recognized As Safe status of talc largely because of asbestos pp 179-180 occupational ocupational \ dozen past occupational 19 occupational CONTROL TOXIC SUBSTANCES ACT OF 1973 HEARINGS BEFORE THE ENVIRONMENT SUBCOMMITTEE OF THE COMMITTEE ON COMMERCE UNITED STATES SENATE NINETY CONGRESS FIRST SESSION ON S. 426 and Amendments 1 8 and 9 TO REGULATE INTERSTATE COMMERCE BY REQUIRING PRE- MARKET TESTING OF NEW CHEMICAL SUBSTANCES AND TO PROVIDE FOR SCREENING OF THE RESULTS OF SUCH TEST- ING PRIOR TO COMMERCIAL PRODUCTION TO REQUIRE TESTING OF CERTAIN EXISTING CHEMICAL SUBSTANCES TO AUTHORIZE THE REGULATION OF THE USE AND DISTRIBUTION OF CHEMICAL SUBSTANCES AND FOR OTHER PURPOSES S. 888 TO BE KNOWN AS THE TOXIC SUBSTANCES CONTROL ACT OF 1973 FEBRUARY 23 26 AND MARCH 21 1973 Serial No. 93 18 | Printed for the use of the Committee on Commerce 94-872 es U.S. GOVERNMENT GOVERNMENT PRinting office WASHINGTON : 1978 RALPH NADER FRITSCH JUNE JUNE , Dr. ALBERT FRITSCH your buildings return attention Washington This INI GENTLEMENpractice to is in reply 29 letter calling D.C. GENTLEMEN using spaces in new buildings as returnreturn calling atention ceilihnagzard asbestos using of of iintrnodutcinrg oducing asbestos asbestos air practice potential protectionplenums to consequnt Abers Abers consequent air is concerned about aabboouutt aiairrbbornoerne asbasbestosestos On hazardous in the initial list of hazardous March March N asbestos This air regulations Agency Federal we Clean Air Act as amended Fedral 31 t included Fear contr section the ambiaembnitent air air of any any hahazardozus arhdaozuasrdous pollutant polutants pollutantsQ Ny into pol utant listed contr section 112 thMearch 31 1972. During the past year emissions into listed for fifty urban promulgated asbestos in some have fielfideld sampling sampling programprogram program samples are analyzed at a rate of of about 20 to nonurban an These being samples samples questions Environmental whether thethe Environmental samples month that your letter require modifications authority building Environmental modifications I note authority to require in design Protecti of note indoor contamination air Nevertheless in control potential inside buildings Columbus been made in have already urements urements California Berkeley and in San Diego and Santa Clara study to measure in California urements pilot asbestos Our a are to initiate as soon as a plans ent outside public buildings competent cag contractor inside and contractor continued can the . that we welcome continued efforts of found environment Center me again say to help identify problems of the us Study of Responsive Law to deal with such problems environment s develop effective programs Sincerely yours WILLIAM D. RUCKELSHAUS APPENDIX 1c Administrator puildings puildings sumdmisacurssyion fulclonytainiDnegcember raised raised puildings to summary promulgatesi rreespsopnodnd to your letterof December will also I belbeliieve eve I covered 15 It discussion the pointspoints R our standards for hazhazardous ardous pollutants your raised in your standards on of spraying materials soon be shinus . emision emission a ban buildings This should eliminateeliminate containing over promulgatesi promulgatesi asbestos future situations Jalter 1. contain of construction or magnitude of the problem asbestos contain Contrary situations exist Contray construction just don't measurements earlier during existence Contrary the sampling program has been limited our air is indica- EPA's EPA's The buildings during asbestos asbestos chambers in air unknown successful promulgation from you of the is With successful outdoor air promulgation sems potential regulations tlons Erosion theinto seems appropriate reduce emis se ms programs asbestos into resources into to define the atat this time magnitude problem problem of asbestos of of our resources also in ke pingkeeping keepingke ping with with a recent formalization magnitude of Indsor in pollutants sampling concern sions some some This is of will initiate a modest We sampling samplingprogram indoor on asbestos in indoor air and attempt to base itit to past data a practices the need for and advisability of control construction practices control regulations all ambiguous at this time However and question problem are determine whether we have a considerations problem premature authority until we discussion on then until a later date and we will premature monitoring premature further develop a study and keep you informed of to prog postpone informed will schedules We will Mr. Robert Neligan Director Monitoring and Data Analy- of Air Quality Planning and Standards be responsible schedules OfficIe have presumed on your knowledge andinterest and interest sis Division assured the program willing be willing to make recommendations to would would that program for of sampling sites and be available for additional disens Bob selection that tractor sions the problemprowbleim th you and hope we can continue the exchange enjoyed talking enjoyed I Sincerely yours B. J. STEIGERWALD Air Quality Director Director Air Quality Planning and Standards December CENTER FOR SCIENCE IN THE PUBLIC Washington D.C. INTEREST 192 Mr. WILLIAM RUCKELSHAUS Protection Agency Administrator Environmental Washington D.C. to a I sent a letter to you on March 24 1971 DEAR MR RUCKELSHAUS hazards arising from ciculation of air in buildi requested your attention to asbestos interior surfaces It was through areas with exposed asbestos on to what extent these pleners mention that you embark upon a program to determine June 1 1971 you asbestos In your reply of insi concentrations are contaminated by having plans to initiate a pilot study to measure asbestos seriously as and outside public buildings After an 18 month lapse we are . cerned req about your findings has the authority to contamination It is evident from your letter that your agency control potential modifications in building design in order to have been initiated indoor air I would like to know what corrective actions final correspondence published the result of the above study One request May I have permission to use our ap endix to a report on asbestos which is to be correspondence in 19723 in January promptprompt reply would be deeply appreciated requests Thank you for consicodnesriidenrgingconsidering tthheessee requests . Sincerely Sincerely yours Ph.D ALBERT J. FRITSCH APPENDIX 1D AGENCY , STANDARDS ENVIRONMENTAL PROTECTION AND , OFFICE OF AIR QUALITY PLANNING JanuryJanuary Research Triangle Park N.O. J. FRITSCH Venter ALBERT in the Public Interest Washington D.C. com erc D.C. DEAR DRFRITSCHFRITSCH: This is is to confirm our telephone selected problem of asbaesbestosstos concentrations in indoor air com erc conversation conversation commerc APPENDIX 2 CENTER FOR SCIENCE IN THE PUBLIC INTEREST Washington D.C. October 1 1972 HDEeApRaIrNtGmeCnLt EoRfKHealth EducatiEducation on and Welfare proposed cour sanctioned food different Rockville Md to comment on the new rega- DEAR SIR OR MADAM : We are writing to lations Federal Register August 12 1972 relating tale ingredients and a change in the prior sanction for fractions substantial fractions of tre- many tales contain samples of It has long been known that * analyzed 51 molite asbestos Schultz and Williams in greater trace than merelal tale and found tremolite asbestos present study on tale these work- of 17. Kleinfeld et al 2 performed a mortality The tale these work- amounts found a substantial excess of lung cancer New and ers handled contained 25 to 35 tremolite. in Seli- were hazards men exposed asbestos workers even more severe Among workers observed investigations + of mortality of insulation % of the observed materials exposure Gastrointestinal handle containing who chrysotile and amosite exposure handled 1.2 cause deaths to 11.2 was the occupational asbestos based cancer attributable Mortality the cause of death in 37 cases of the mesothelioma Mortality peritoneum cause of data and malignant is an extremely In the an additional 14. This latter havehave been would generalgeneral population There certainly risks none expected enses in it not for competing above categories were ( versus versus8.9 expected pleural mesothelioma was the cause of death of larger numbers and asbestosis 27 versus none expected 1 4 75 194)2 Schulz Conference Kleinfeld R. and C. R. Williams J. IndustriIanldustrial Hygiene 663 International Conference International Private Kleinfeld M.M. et al Arch Environ Health Castleman AugustAugust International International International Castleman Private to B. of the Communication Kletufeld M. 150 Proceedings 150 Johannesburg p Pneumoconiosis JohannesburgJohannesburg et al Pneumoconiosis Capetown Oxford Johanesburg 1000 Press University ( 181 literature for for the literature the National AiAirr that th nay Pollution stated stated flber necessary not mbaleiegnnanPoltutidonetermined for Control tration asbestos review In a was it by for flber tale will continue en'ny tration concerned that malignant the than strong similarity in tumo status more are are concerned compsitons We safe is There There Tale Tale particples articles live live been compositions as safe compositions ognized and tatale le a number of pfients pfients pfients silcates and silicates taken from number found pfients with de ply : ognized found tiform tumor tissne particles were in se tumors ovarian ovarian within asbestos epidemiological epidemiological studies Akers Akers with fe COIUDYGN among men as mundoubtedly mundobtely mundoubtedly COIUDYGN times who considered figures considered not figures to competing higher times simultan only subjected competing These simultan and \ do work if with not simultan slipstosis risks higher work | the level limpossible limpossible of were cancer limposible to estimate the level asbestos asbestos continuously mesothelioma were limposible in asbestos asbestos mesothelioma intestinal continuously exposed can exposed , no inptesotinpalulation population which exposure which smoking the cigarette with no increasd exposure to National population increased risk population which The general population populatiron isk of lung luncgentlycacnacnecrer The which exovteernddue favor parenteral thliosng beer presently presntly asbestos foods perfumed thaWte presntly Administration yours safe presently adoption However that adoption Howeverfor use view foods perfumed above reports coneinde coneinde presently i suspect a ban of ban on begining in extend als in beginning beginning beginning we activities sure urge its activities to a sure that the begin ing whiskey Administration to and Adminstraion of such items drugs increased to such diseases Health including Asbestua information Exposure to prevent other than one of including standard information that inclusive it is stated Asbestos In Preliminary all inclusive it the inclusive of Asbestos fiber is necessary necessary induce to induce than to designate Survey apropriate malignonalynttumor determined was appropriate whose more the subject of a regulation insufficient asbestos has has Ocupational Ocupational Occupational Derupa- to estab not Prelimnary Air Pot hazardous J. MICHAEL F. MICHAEL FRITSCH ritual promulgating mawtoerrkiearlss APPENDIX 3 CASTLEMAN JACOBSON CASTLEMAN JACOBSON Protection tougher strongly others work- Ba] vironmental and CENTER FOR SCIENCE IN oo Washington PUBLIC taminationtamination ALBERT on asbestos INTERN Washington D.C. INTERNINTERN RUCKELSHAUS , November Environmental NovemIbNerTERN FENISCH Director Mr. Wx D. Protection Agency, 9 1911 Administrator Environmental Administrator D.C. , 1911 - Occupational Washington RUCKELSHAUS We have been following for vo DEAR Administration Administration MR toward National Emission Standards for some time progres progress standards er's are particularly concerned about proposed hazardous your age tants for which We a major contaminantcontaminant in our environment environment standards Our air for pol IN THE PUBLIC INTEREST which of Pollutants the proposed Standard for Hazardous Air Pollutanhtass asbestos copies and Mercury as sent to you for final approval received of the Baltimore County Health Berylium comments Asbestos Department Further is seen Department this ment There is f November this doe November 6th andltehtitnekr Occupational be consideration should given no need to repeat the deficiencies with We concur with all the contents consideration consideration im ediate immediate is referredreferred ofof that on to inin their their leltteertter we banban | Overall our impression is that the water- ed versionversion thitnhkink sent to you for approval is not really a regulation is of the Standard business as original y Asbestos DusWte 1972 the condito condito well Standard All six sections of the as weakened the Federal Register of December 7 1971 have been to operate proposed propsed | established weakened completely We remind you that under the law the emisseimoinssion in pollutants must be regulated by the EnviEnvironmentalronmental ProtectionoAfgency hazaharzadrdoouu hazardoiu the exposure protect Agency provide an ample margin of safety to the public health Agency more County letter makes clear you will be put in an position embarasemibarngsing pospoisittoinon deaths embarrassing called upon to explain how the sanctioning of visible positon dust from health asbestos emissions position demolition or any source is protective of the public There is little need to remind you of the voluminous medical literature literature asbestos We are all familiar with many reported cases of mesoth literature malignant lioma of the pleura and peritoneum a disease extremely rare mesoth or numbtheer 5 in handled population but quite common among asbestos workers Also a soms have this disease whose only known exposure to asbestos was em mental that is they have lived or worked near a mine mill manufactu Lung plant or fabrication area where asbestos was cancer men whowho are occupationally exposed to asbestos and smoke 100 times as common as cigarettes asbe i be government'sand it among men who neither smoke nor handlehandle protection promulgating standard health of asbestos protect many Insuficent to protect of asbestos construction Insuf icient Agency to adopt a much occupational and We vicinity vironmental Protecionand to do so at the earliest possible date position has exposure which tamination tamination Sincerely yours ALBERT JJ.. FENISCH E.C. BARNYBARNY CASTLEMAN Director to Mr. Guenther , M.S.E. Letter Appendix Letter Safety and Health Administration _ APPENDIX 4 CENTER FOR SCIENCESCIENCE Washington D.0 July, ,197 ; E. GUENTHER GUENTHER Secretary of Labor Adminstraion Mr. AssistantAsitan Secretary and Health Administration, Assistant Occupational SafetySafety D.C. Washington Washington We deplore youryour recerencenttlly y promulgated Standard for : DEAR Federal Register Vol 37 No. June: 7, 1972 It is to the medical literature that workers face a greatly enhanced risk of developing fatal asbestos diseases per cubic eenth prescribed followed pleas by the AFL for a one fiber Your Union for action limit limit and by the Oil Chemical and Atomic Workers . ter ( cc limit as well as statements by recognized authorities of of Mount Mount Sinai Environmental Sciences Laboratory to the effect that 40 of of insulation workers in this country whose weighted exposure to is 3 cc are attributable to occupational asbestos exposure This fact was revealed at the March 1972 Hearings National Ocupational The Criteria document prepared by the National Institute for Occupational Safety and Health Occupational Exposure to Asbestos makes it clear that while a 2 cc level cannot be declared safe it is undoubtedly less hazardous than cc and all haste should be made to reach that level industry Tabershaw reviewing the literature on asbestos in 1967 compared asbestos radiation If there is a safe threshold above natural background to which large human populations can be exposed with no enhanced risk to developing certain diseases this threshold is not known it will not soon to appears be quite low We are perplexed and alarmed by government's the