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