Document J3npadrRzdODN0JgXq8En5NrO

FILE NAME: Brand Insulations (BIN) DATE: 1972 Feb 11 DOC#: BIN004 DOCUMENT DESCRIPTION: Letter M 'J] i *< V *.V, <4 r.s s' .-v- ' -J eure jta N4-'C o n\fne-* P homx ;;g-3sis 5 0 W . rU L T O N *T C T C h i c a g o , t u . &ofca February 11, 1972 EXHIBIT Office of Safety & Health Standards 400 First Street Northwest Roca 30S Washington, D. C. 20210 ' f a f a f t d ! . SA He: Proposed Standard For Exposure to Asbestos Dust Gentlemen: As thermal insulation contractors in the construction industry and being effected tremendously by the above standard, we are herewith submitting comments in accordance with notice published in the Federal Register, Volume 37, No. 7, Wednesday, January 12, 1972. Current thermal insulation specifications, particularly these ap plicable to industrial, utility and corps of Engineer process work are Teplete with reference to material containing asbestos. The asbestos is primarily evident in cements which are converted to a workable consistency after mixing with water at the const ruction site and in rigid, preformed sections of insulation as a binding agent. Thus it is obvious that the following is unavoid able: (aj asbestos fibres are or can be airborne immediately upon opening a bag of cement, and (b) any handling, cutting, trimming and fitting of the preformed sections of insulation also precipi tates these free particles. Consequently, pertaining to the above notice; Paragraph c, warning signs would surround each construction site on which asbestos containing material is used. Paragraph f, all persons engaged in employment of a const ruction site so posted must be monitored. Paragraph d (6), as the dust would be ubiquitous, complete vaccua cleaning of a posted construction site would be a daily occurrence. This monstrous task would be a nightmare and totally unfeasible. Alternately, enclosures to capture dust are equally unfeasible. Minimally, these actions would generate costs incalculable, yet STAGGERING. There is no criteria available for determining how many tradesmen will be subject to airborne asbestos dust. Like wise, this cost responsibility must be assigned, i, e. shall each contractor incorporate his amount as part of his bid? Or, shall only those contractors using asbestos entrained material be liable":  ii S' . v.f < :& v vv ! (299) If so, in what proportion? Ridiculous? Only if this standard is hyprocritical. As opposed to further cost accruing examination of other paragraphs in the shove notice, we submit the following; A. Substitute asbestos type cements with other types if possible. Another alternative would be the employment o a mineral wool or fiberglass wrap finished with either a poly-vinly-chlorids (PVC) jacket or metal jacket. This is being done presently, but only on a relatively small percentage of construction. B. In lieu of using pre-formed insulation which has the asbestos binder, substitute fiberglass on temperatures below 450*F. and mineral wool on temperatures above 450?. C. The education of poisons engaged in specification writing and cooperation of insulation manufacturers whereby effort will be expended to the end of the availability of new products is alsi necessary. Finally, construction work in progress, which is not exempted by t5 standard, it still another entity. The same cost proportionately are involved, however immediate. As these additional moneys are nt reflected in current contract amounts it is financially impossible to absorb this. Even if it was, it would be grossly inequitable. Inasmuch as the construction industry is confronted with this momentous challenge, coupled with the fact that normally the insul. ation contractor commences work approximately six (6) to nine (9) months after a given construction project gets underway, we feel the committee should be advised to consider an extension of time before enactment of said standard. Hopefully, at the very least, it would take any months to assemble the data required in order to assess this additional cost burden to the insulation trade alon< Ke cannot intepret the standard with regard to its effect on the other trades, but it is pointed out here that several others are possibly involved. Kith all due respect to the authors of the standard, some of whom no doubt include industrial hygienists and medical doctors, the construction industry is unique, compounded with even further specialization within the industry. As can be readily seen, a task so compTeheasive cannot be accomplished in a few weeks. Kc appreciate this opportunity to apprise the committee of pur situation, but it is also our duty to submit this presentation. . ' . . V Very J! ..<? truly yours, . h* ( , ^