Document Gw1Gx5g9NyJrqxzNNyZe3Oqx
FILE NAME Brakes BRK
DATE 1971 Oct 15
DOC BRK034
DOCUMENT DESCRIPTION Presentation to Illinois Pollution Control Board Dr. F.L. Pundsack
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:
Dr. F. L. Pundsack
.
Presentation to Illinois
Pollution
Control
.
Board
October 15 1971
aan
My name is Dr. Fred L. Pundsack Research and Development for the
and I am Vice President of
Manville Corporation
I am an inorganic chemist with Ph.D. degree from the University
of Illinois and I have been involved in asbestos research
since 1952. I am here today representing the Asbestos Informa-
tion Association an organization sponsored by nine leading
manufacturers of asbestos products to provide information on
asbestos and its health implications The members of this
Association are listed in a fact sheet which I have provided
In the event that my presentation prompts questions relating
to environmental control technology or the medical aspects of
the asbestos situation I have asked three expertisn these
fields to accompany me here today to assist in answering ques- ques-
tions of a highly technical or medical nature They are Dr. Joseph L. Goodman Associate Professor Department of Proven,tive Medicine Medical University of South Carolina and
Medical Director Raybestos Corporation Mr. Isaac H.
Weaver Corporate director for Environmental Control for the
Raybestos Corporation and Mr. George L. Swallow
Manager
Manager
Manag Managerer
of
of
Occupational Occupational OccupatioOcnupaatilonal
Savionmental
Savionmental
Savionmental
Savionmental
Savionmental
Savionmental
Control Control Control
Johranilin
Johranilin Johranilin
Johranilin
Johranili Johran nilin
Corporation
dre 1 ua
Before proceeding I would like to express the appreciation of
the Asbestos Information Association for the opportunity to testify
on the proposed asbestos regulations
Asbestos has numerous important applications in our modern
industrial society Among these it provides built pro-
pro- tection against fire and deterioration in scores of common
ducts in daily use Through the years it has saved countless
lives and billions of dollars in property damage by preventing
or checking the
products make a
spread of fires containing acoustical
i
-
valuable contribution to noise abatement
Products containing asbestos are used among other applications
in the construction of schools houses theaters factories offi
and other public buildings and in the insulation of furnaces
boilers and electrical equipment
The asbestos industry within the state of Illinois plays an im-
role in the economic life of the state and its people
portant
The member companies of the Asbestos Information Association own and operate a total of eight plants within the boundaries of the
state Some of the product lines produced at these eight
plants include asbestos pipe packings gaskets friction materials both conventional and disc brake lin-
asbestos sheet products asbestos roofing and siding shingles insulations and many others A total of 3,118
-2-
Illinois
lities
residents are employed at these manufacturing faci-
Last year these employees received a total of
$ 24.4 million in wages salaries and fringe benefits Services
and goods telephone
purchased within the state such as water electricity service raw materials and freight amounted to more than
$ 17
million in 1970. In addition state county and local taxe
nearly amounting to
a million dollars last year helped to pay for
new schools roads and other benefits to the state and its _
citizens The value of goods produced at these manufacturing
locations last year totalled $ 70.1 million with approximately
products 14.5 million worth of these containing
being
sold within the state
As you can see the economic contribution of the asbestos ustry in the State of Illinois is by no means small And the figures
I have just given you represent only those companies that are
members of the Asbestos Information Association There are also
within the state many other concerns - both large and whose livelihood depends in some measure on the use
of asbestos or containing products Such concerns would
include many segments of the construction industry companies
engaged in the manufacture of containing products
companies which use finished containing products in
the manufacture of other pind cts and many others others others
the
the
Les con
con con
value to the State derived by the use of asbestos by these other
3 3
concerns is difficult to gauge however it would certainly
double or triple the figures I gave you earlier with regard
to the contribution of the member companies of the Asbestos
Information Association
The asbestos industry has recognized for many years that there
are occupational health hazards associated with the excessive in-
halation of asbestos dust over long periods of time
sult the industry beginning in the late 1920s has
As a re-
sponsored
and cooperated in wide variety of scientific research projects
designed to identify these hazards and to eliminate them where-
ever they may exist not only in asbestos mines mills and manu-
facturing plants but also among fabricators and applicators of finished asbestos products Today the asbestos industry either
as individual Association's
companies or through the Quebec
sponsorship of the Institute of
Asbestos Mining Occupational and
Environmental Health in Montreal is supporting medical research
at such highly regarded institutions as McGill University in
Montreal Tulane University in Louisiana St. Luke's Hospital
in Cleveland the Environmental Sciences Laboratory at Mount Sina
Hospital in New York the Industrial Health Foundation in Pitts-
burgh the University of California at Berkley Farleigh University in New Jersey the University of Pittsburgh the Medic
College of South Carolina and number of others both here and
overseas In addition the industry has cooperated extensively
-4-
in various investigations into asbestos conducted by
agencies of the Federal Government including the U.S. Pub-
lic Health Service the Federal Environmental Protection
Agency the National Institute of Occupational Safety and
and others In the industry's own research laboratories
Health
and engineers are also engaging in work related
scientists
to health developing safer packaging and handling techniques
for loosely bound asbestos products and also developing and
improving techniques for the measurement and control of as-
bestos emissions both in the place and in the ambient air
~
a result of these activites over the years the industry
As
amassed has
a substantial amount of medical knowledge and techno-
logical know in the asbestos area
Basically the known facts about asbestos disease can
be summed up as follows
_
ae a
es ~~
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-
asbestos health risks are basically confined to
First
the occupational and occupational setting
Se
ee
ee
ee
ert
ee
eee
_ _~
Second the effects of excessive inhalation of asbestos are
both time and dose related
This
that
means
ee
eee
asbestos
moe
...
diseases only after the inhalation inhalation of
may develop generally
substantial amounts of asbestos dust over a substantial period
ne
of time
.
And third there is presently no evidence of hazard to the general public from exposure to the minute amounts of as-
bestos that may be present in community air
Because the general purpose of the regulations under dis-
cussion here today is to prevent the emission of hazardous
quantities of asbestos fibers into the air that the general
public breathes I will restrict my further comments on health
to this area It is very important to realize in any discus-
sion ofa possible public health hazard from asbestos exposure
q
that the only scientific studies we have to go on are those of -
groupgs roups
in
of people a
occupational and occupational environment
occupational eine oa errno reremnrns oe n
oe
-
There is no basis for assuming that data on occupational health
risks associated with heavy long term asbestos exposure can he
applied to the general public without taking into consideration
the vast differences
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tr ~_
-
.
nw eee
exposure between the
two
Despite the fact that the only studies in existence are of
occupational and occupational populations a careful
analysis of the data available can give us some general infor-
from . mation about the question of a possible public hazard pet
_o
=a=
eee oor _
ee
of that diseases asbestos. The substance
this information
.
associated
associated
with
occupational
exposure
to
asbestos are
dose
re-
lated and that the doses below which no measurable increase in
disease occurs
are
fafrar higher
than any dose
general
to which the general
public is exposed
This evidence is based on a number of epidemiological studies
three of the most prominent being one by Dr. J. Corbett McDonald
of 10,421 past and present asbestos mining and milling workers
in Quebec a second by Dr. M. L. Newhouse of 4,500 men who were employed in a British asbestos factory between 1933 and 1964 and
the Third a study by Drs Knox Doll and associates of 878 workers
in an asbestos textile factory also in Great Britain
Dr. McDonald in his study divided his subjects into eight
categories based on length of employment and severity of dust .-
exposure He noted that only in the highest exposure categor
comprising five per cent of the total was there any increase in
deaths from respiratory and cardiac diseases including lung
cancer
Taken as a group the Quebec asbestos workers had a
mortality rate from all causes lower than the level expected in
.
the general population
Dr. Newhouse in her study in Great Britain found that workers who had low and moderate occupational exposure to asbestos dust showed
a rate of deaths from diseases of the lung including cancer of
the lung and pleura that were comparable with that of the general
public On the other hand another study by Dr. Newhouse of
mesothelioma a relatively rare cancer of the lining around the
_
lungisn the LondLondon on area showed small number of cases anong people who lived in close proximity to an asbestos textile plant
and also among people living in the household of an asbestos works
who presumably brought home quantities of the material on his
clothes from work
The intensity of exposure experienced by these
_7-
called occupational populations in London is difficult
to gauge but there
in fact higher than
factories that have
is every reason to believe that they were
the low and moderate occupational levels in
been shown to produce no excess of mesotheliom
These studies do however point up the need for proper control
of emissions of will not suffer
asbestos from factories so that neighboring
occupational exposures to asbestos
areas
The Doll study like the Newhouse and McDonald studies
- confirmed the fact that low to moderate levels of asbestos
exposure will not produce an excess of disease It should always
be remembered that these low to moderate levels in occupational settings inside factories were certainly higher than any to which
is
the general publipu cblic in thithis s country is exposed
In addition to these
studies
of there are several studies
the
effect of various doses of asbestos on laboratory animals which also indicate that there are dose levels below which no measurabl
disease effect is observed Dr. William Smith of Fairleigh-
Dickinson University studied mesothelioma cancers in hamsters
and his data show that below certain specific doses of asbestos
no cancers were observed to develop over the entire natural life
span of the animals of Health Bethesda
Dr. Merl
Maryland
Stanton of the National Institute
conducted a somewhat similar
observed study with rats and
the same type of related
response
The most known of the American epidemiological studies
related to asbestos exposure is that made by Dr. I. J. Selik- off
of 632 members of the Heat Frost and Asbestos Insulation Workers
Union in the New York Jersey area These men for the
most part are journeymen who work
sites and apply insulation to boilers steam
on construction and hot water
pipes heating ducts etc. during the construction of a
building or a power plant They may also be involved in
tearing off old insulation When one construction job is
completed they move to another construction job
:
The occupational environment to which they may be exposed
involves not only asbestos but also silica and particulate
In addition they are exposed to a variety of fumes from
materia
, organic solvents and adhesives with which they work In ,
short they have a widely varied and in the past at least
ee
ee
ee - weeoooouncontrolled _o - ee ~~
a relatively uncontrolled occupational dust and fume exposure -7 _
eee _
-
- ~_
oe
-
_
Si
ee
=
Dr. Selikoff found that the death rate from lung cancer
extremely high in this group of 632 workers but that this
was
very high mortality rate occurred almost exclusively among
those workers who were cigarette smokers
On
the
the
oothetr her
hanhand d
tthhose osthose e
workers
workers
workers
who
who
had
had
no
history history history
history
of
of
cigarette smoking had essentially no greater incidence of
lung cancer than the general population of smokers
In general the mortality rate of insulation workers reported
by Selikoff is much higher than the rates found in
studies of larger grouposf people who work in factories
producing containing productansd in mines and
the hat mills processing asbestos Why
incidence of certain
diseases among insulation workers so much higher than the
other groups studied is question as yet unanswered
case Unfortunately as is so often the
with diseases that
take from 10 to 40 years develop reliable data as to
the past occupational exposure of these men to asbestos
and other potentially hazardous dust and fumes in their
work are not available
As a result at the present time we have little information
as to what other factors may have influenced their high rate
of disease except that those insulation workers who smoked
cigarettes developed lung cancer at a rate far higher than the general population who smoked
In 1970 with a grant from the National Air Pollution Control
Administration The National Academy of Sciences called together a ribbon panel of asbestos experts to draft a document or the problem that would serve as the
-10-
medical basis for the Federal asbestos emission standards
those asked to serve on the panel were Dr. Clark Cooper
Among
of the University of California Dr. Lewis Cralley of the
Public Health Service Dr. George Wright Dr. Irving Selikoff
and others
- The result of their study was a three page document
on asbestos As a conclusion to this part of my
presentation I would like to read a few pertinent excerpts
from the report which constitutes the most date evaluation of the asbestos problem that is available
ee eee
wee ee ee ek
On
page 20 the report states quote
We cannot extrapolate
Onfrom from the mortality experience of those who are directly
/
? and indirectly exposed in their employment to the general
:
public who have had moderate or slight exposure from ambient o
-
is
air There is
evidence
_
ee ne ee eee ffect Le
to suggest a gradient of effect gradient
i
from direct occupational to indirect occupational to family
~~
ee
and neighborhood situations
ce
in all of which dust concentra-
tions are probably high by compwia th r mosi t cs ommo unin ty
* air This suggests that there are levels of asbestos
~
- exposure that will not be associated with any
-10a-
detectable risk What those levels are is not known but there
population is no evidence that persons in the general
occupational household or neighborhood exposures any
increased risk of neoplasm even though there may be ferruginous
bodies or fibers in their end quote
In the conclusion and recommendation
for the National Academy of Sciences
section of the report
the following statements
are made
quote At present there is no evidence that the small numbers
of fibers found in most members of the general population affect
health or longevity Asbestos is too important in our technology
and economy for its essential use to be stopped But because
inhalation of the known serious effects of uncontrolled
of
asbestos minerals in industry it would be highly imprudent
to permit unrestricted additional contamination of the public
environment with asbestos end quote
I believe that these statements from the report adequately express the position of the asbestos industry with regard to the
health hazards of asbestos We do not believe that at present
the general public is in danger from the minute amounts of
asbestos that exist in the ambient air However we also believe
that it is prudent.and feasible to establish reasonable emission
controle will protect the public and ensure that hazardous
levels of asbestos will not develop in the community air in the
future
-11-
With this position in mind I would now like to discuss the asbestos regulations proposed for the State of Illinois ----
begin with I would like to commend the Illinois Pollution Control
Board for its efforts to ensure a safe environment for the
State and all its citizens Your credentials as a progressive _
yet fair control board are well known and respected in environ-
mental circles throughout the nation
While the asbestos industry as represented by the Asbestos
Information Association is of the position that there is presently
no hazard to the general public from the minute amounts of
:
a
asbostos existing in the community air we nevertheless are in
favor of regulations designed to accomplish one or more of the
following three objectives
One to ensure the health and safety of those occupationally
exposed to asbestos fiber
Two to prevent possibly hazardous amounts of asbestos fiber from escaping into the ambient air and
Three to eliminate where possible the nuisance of even small amounts of asbestos fiber from escaping into the ambient air
While this third point is not directly related to health because
of the small amounts of fiber involved we wholeheartedly support
the position that the environment should be clean as possible
For these reasons we support most of the items in the proposed regulations However we do have several specific comments and
12-
suggestions to make regarding the regulations
a will be of help to the Board in arriving at
that we hope
final document
that will not only
I will discuss the
be effective but also practical and reasonable sections upon which we wish to comment the
order in which they appear in the regulations
Our first suggestion is with regard to Part II General Require-
ments Section 201. This section calls for the obtaining of a
permit to engage in any activity which could discharge asbestos
fiber into the environment We feel that this section is not
.
specific enough with regard to which activities would be covered asbestos- As you are probably aware in the vast majority of
containing products used in the country the asbestos is locked
in place with cement plastics or other binding materials and
does not constitute a source of emissions to the atmosphere
Asbestos pipe and asbestos floor tile are examples
of such products Other products and activities do constitute
possible emission sources and under
a permit If it would be of help to
the
the
regulation
Board the
would require
Association
I represent products in
would be most willing to prepare
common use where the asbestos is
a list of those
in locked
or loosely state and thus constitute a possible emission
source which would require a permit
As to Section 201 section B requiring a satisfactory
course of health instruction for employeeisn those
industries involving the handling of loose or loosely asbestos products I would like to point out that
the various trade associations in the asbestos industry have over
the manuals and book-
years produced a number of safety practices
industry lets dealing with various sections of the The Asbestos Information Association would therefore recommend for your con-
sideration as instructional materia folr use
section B the safety practices booklets
under
which
Section 201
I have sub-
mitted to the Board with my presentation The four booklets are
1. Recommended Safety Practices for Handling Asbestos Fiber
2 Recommended Health Safety Practices Handling and Fab-
ricating Asbestos Textile Products
~_
3 Recommended Practices for Fabricating Handling and Apply-
ing Asbestos Products in the Building and Construc-
tion Industries
4 Recommended Health Safety Practices for Handling and Apply-
|
ing Thermal Insulation Products Containing Asbestos
Under Part V Section 501 it is our opinion that Subsection B
which requires the enclosure of walls before toppling during
demolition is both impractical and unnecessary We know of
no suitable method
during demolition
for enclosing the walls Even more important is
of a structure
the fact that there
is in reality very little
of a modern medium or
used in the
asbestos
high structure
construction
In addition
dust counts taken during the demolition of a building in
" .
-14-
Easton
Pennsylvania Pennsylvania
of asbestos products
which did contain significant
. .
showed very little dispersion
quantities
of fiber
into the surrounding air both upwind and downwind of the
' demolition site This is due to the fact that most asbestos-
products containing
in which the fiber is locked with ce-
ment plastic or other binding materials do not readily re-
atmosphere even lease fiber section
in the
of Section
501
requires
during demolition Sub-
the prior removal before
toppling of boiler and pipe insulations asbestos-
containing products that might release dust from improper
demolition - Since this will remove any loosely asbestos products from the structure we believe enclosure of the
walltso be unnecessary and recommend that simple wetting
of the walls to be toppled would be sufficient to control the
dispersion of dust from whatever small amount of asbestos-
containing products the walls might contain
regard " With
to Part VI Section 601 of the regulations we
would like to recommend for your consideration a completely
new approach to the control of asbestos emissions from manufactur a
-15-
.
* operations As presently written the regulations call for
the establishment of a numerical emission standard of .5 fibers
per cubic centimeter of air from
any manufacturing operation
and .05 fibers per cc of air at the boundary line of the plant
or factory
.
i
wee 23
~ae
UD.
Se
Section regulations We would recommend that
601 ofthe
be re-
.
written
so
as
to
substitute
a
|
control practice
standard
for
the present numerical emission standard The reasons for this
recommended approach are varied but are
primarily based on the
techniques at very low fiber concentrations
The Federal Environmental problem very carefully in
Protection Agency studied this preparing its national emission
standards on asbestos and arrived at the conclusion that
a numerical standard was impractical at this time In this
regard
I would like to read a few excerpts
from a document
preparebdy the EPA as justification for this viewpoint
-16-
The document states that ideally national emission standards
for asbestos would be established on a concentration basis
related to health effects and would provide an ample margin of
regardless protection to the public health
of the number of
sources in a given geographical
considerations the report goes
area There are many practical
the on which prohibit
establish-
standard ment a numerical
at this time
is the lack of a data base base
Foremost of these problems
is lacking from
tional exposure
both the effects standpoint
and the emissions standpoint The
for occupamajority of dat
available on
exposure and
asbestos health effects is related to occupational cannot be readily extrapolated to occupational
levels
little that quote a control prac-
A
later on the report states
levels offers
tice apprach to reducing asbestos exposure
alternative tical
to numerical emission limits
A major
tage of a control practice standard would be realized in
a pracadvan-
enforce-
ment
could be easily trained to certify compliance
Inspectors
with control practice regulations end quote
on to describe some of the many difficulties invc The report goes in asbestos sampling and analysisanalysis especially with regard to emissions into the ambient air and concludes that present techniques are not only time consuming and expensive but that they
--17-
the atmosphere also tend to distort the concentration of asbestos in sampl
being analyzed and are hence not
meaningful in establishing the
actual amount of asbestos
being emitted into the
The National Academy of Sciences Committee report on asbestos
health which I quoted from earlier agrees with the EPA positio
on numerical standards
and other uncertainties
It states quote because of
methodolog
it is not yet feasible to base
control
on numerical ambient air quality standards end quote .
<.
a
I will not go into detail on the specifics of control practice
standard since they would be primarily of an engineering nature
soon however I will submit for
your consideration as
as they a
published the asbestos emission
standards proposed by the Envi-
ronmental Protection Agency
ficient information to set
up
These
standards will contain suf-
a similar program for the State of
Section 602 of Part IV of the
regulations deals with the dis-
charge of containing waste into the sewage systems or
waters of the state
We believe that this section is un-
necessary
first In the
place the water pollution
-
control
systems in use in most asbestos
manufacturing plants across
the state effectively remove the
majority of asbestos wastes
from the effluent before
discharge into state waters
-18-
Secondly sewage plants also remove asbestos fibers from
waste water during purification In reality the high dillution
of small quantities of asbestos fibers in water is as effective
and safe a method for the disposal of asbestos wastes as could
be devised There is no evidence that the swallowing of small ~
amounts of asbestos constitutes any health hazard whatever
_-
In addition studies conducted by Manville have found
small amounts of asbestos fiber in samples of water tested
from sources all over the United States including well and
spring water The reason for this is quite simple Asbestos-
bearing serpentine rock is to be found in a majority of the states of the union including Illinois and the simple process of water flowing over and through these rocks errodes a certain
amount of asbestos fiber
Thus we have all been drinking tiny amounts of asbestos in
our water since birth without any discernable adverse effects
In Part VII Section 701 of the regulations we would recommend
the addition of the
so that the amended
word visible in the next to the line
section would read No product which may emi
-19-
asbestos during its transportation shall be transported unless
in such a manner as to preclude the visible such product is enclosed
fiber into the ambient air The problem here is
emission of asbestos
and enforcement The EPA has gone
once again with analysis techniques
to a quote no visible emissions end quote standard in circumstances
similar
also be
to this
applied
one and we would recommend to the Board that this
in Illinois This would also be useful in other
_
sections of the proposed regulations
would tend to be extremely difficult
where measurement and
if not impossible
enforcement
Our final comment is with regard to Part VII Section 702 which would prohibit the use of asbestos in the brake lining of vehicles --
manufactured after January 1 1975 and sold for use within the State
of of Illinois We believe that on the basis of the existing scientific
In 1968 this evidence such a prohibition is completely unnecessary
by question was investigated thoroughly
the United States Public
on these investigations by Jeremiah Health Service and a report
R. Lynch entitled Brake Lining Decomposition Products was publishe
report Journal in the
of the Air Pollution Control Association The
stated that quote except
ditions only a very small
in all but the most extreme driving confraction of the 30 to 50 per cent asbestos
present in a
end quote
brake Lynch
lining escapes
found that the
into the atmosphere as
average amount of free
free fiber fiber releas
cent was less than one per
of the fiber present in the brake
lining composition The percentage was higher only under
conditions that would have resulted in brake failure Lynch
further
-20--
eo
.
t
of the fiber in linings was converted
reported that the majority
fibrous into an inert
material by the heat of friction and
concluded that the use of containing brake linings was
an inconsequential health factor in urban air pollution His
million conclusion is reasonable in light of the fact that hundreds of
of cars using containing brake linings have been stopping
century and starting in this country for more than half a
and yet th
has been no epidemic of asbestos disease among the general
public nor have significant quantities of asbestos been demonstrated
to exist in the community air While we consider this evidence to
be conclusive if the Board is still concerned about asbestos emissior
be interested to know that the Federal
from brake linings you will
Environmental Protection Agency has contracted
poration to do additional tests
for completion in June of 1972
in this area This study is due and we would recommend that the Board
at the very least await the outcome of the EPA study before making
a final decision on containing brake linings It is our
that belief
the Bendix study will confirm the conclusion reached by
Lynch as to the safety of containing brake linings .
- This concludes my presentation on the proposed regulations I
have submitted for your consideration copies of all the medical paper
reports booklets and documents that I referred to in my presentation I would once again like to express the appreciation of the Asbestos
Information Association for the opportunity to appear here this
morning Thank you
- 21