Document JJ3yMoGOvOpL9gnwr7B3KGDje

A Johns-Manvilie Research t Engineering Center P. O Bex 155 Manville. N J 08835 (?01) 722 SOOO r >. y >Hi/ /. I\ May 16, 1972 (dictated 5/12; Mr. R. W. Knapp Quality As.c;urance & EnvironmentalControl Manager Aluminum Company of America POB 150, Mnssena, New York 13662 Dear Mr. Knapp: Thank you for your letter of May 1 concerning the mate rial I submitted for the OSHA hearings on asbestos. Enclosed is a copy of the list of locked-in and nonlocked-in asbestos-containing products, along with my letter of transmittal to A. Goldberg, the hearing examiner. If you have any questions after you review this material, please do not hestitate uo contact me. if./-i /* Very truly yours, F. L. Pund.uack C r<-- , Vice President, Research u Development ae Enc Si X 1^-Utu C. -u..} ALCOA0000478 r^-e A"' tMKer'l</J/: . ^ - .. 5\ John?. .Vanville HettarcA 4 '.rglnewring Center P. c Po* 1 a9 inv.-if!. N 09835 <20;.22 9000 March 2\, 1312 Mr. Arthur Goldberg -.oaring Examiner U.S. department of Labor OSHA Hearings Room 305-306 Railv/ay Labor Building 400 First Street, NW Washington, DC 20001 Dear .'i . Goldberg : Enclosed is a list of "locked-in" and "non-locked-in" asbestoscontaining products for incorporation into the record of the OSHA hearings on occupational standards for asbestos dust which were held March 14-17, 1972 in Washington, DC. As you recall, in my testimony with regard to some of the pro posed labeling requirements for asbestos-contairmg products I argued that no labels should be required for products in which the asbestos is "locked-in-place" by a binder such as portland cement, resins and plastics. On the other hand, I did support the use of proper cautionary labels on products in which the asbestos is not firmly locked-in-place, and in which the worker who handles and applies the material may generate significant quantities of asbestos-containing dust. During the questioning which followed my testimony, I agreed to submit a list of "lockedin" and "non-locked-in" products which could be incorporated into the hearings. These are the lists which are attached. We have used the following general definition for "locked-in" products: "Iocked-iu" asbestos-containing products are those products in which the asbestos is firmly fixed in place with some type of binder, saturant, coating or Ponding agent such that normal handling and ap plication does not generate significant quantities of asbestos-containing dust. Examples of binders, saturants and coatings used in "locked-in" products ire portland cement, phenolic, polyester, epoxy and other thermosetting resins, thermoplastic resins, asphalt, bituminous concretes, and latex and similar polymeric coatings or bonding agents. ALCQA0000479 Johns-Manviile P O Bo 159 Wanvillo. N J 0883S (201)732 5000 Mr. Arthur Goldberg March 24, 1972 Page 2 Although we have tried to make the enclosed lists of products as complete as ve can, it is possible we have overlooked some uses. Thus, if OSHA accepts and uses the distinction between locked-in and non-locked-in products, a provision should be made for adding products to the lists in the future. It should be understood that the range of asbestos contents listed for the products is ah approximate range. We believe these ranges to encompass most formulations, but it is possible that a given manufacturer may be operating either slightly higher or lower in asbestos content than these ranges. Thank you for the opportunity to submit this material for the record. Very truly yours. F. L. Pundsack Vice President, Research & Development ae Enc KLCOA0000480 ' L`% Ah *sJ^! Johns-Manville Research & Engineering Center P O Doe 159 M.meille. N J. C8835 (201)722 9000 Mr. A. Goldberg March 24, 1972 Attachment 1 "LOCKED-IN" ASBESTOS PRO'-UCTS PRODUCT ADHESIVES Various resin systems ASBESTOS-CEMENT PRODUCTS Architectural panels & facings Canal bulkheads Cooling tower fill Extruded shapes Pipes & ducts Pipe fittings & couplings Sheets -Corrugated Sheets -Flat - Flexible Sheets -Flat - Rigid Shingles -Roofing Shingles -Siding ASPHALT PRODUCTS Asphalt roads & curbing Fibrated emulsions Flashing cements Mastics Roofing cements Roof coatings CALCIUM-SILICATE SHEETS High density sheets (50#/fc3) COATINGS Premixed underbody coating APPROXIMATE RANGE OF ASBESTOS CONTENTS IN PRODUCTS AS USED 1-3% 15 - 20% 15 - 20% 15 - 20% 5 - 20% 10 - 20% 15 - 25% 2C - 30% 20 - 35% 15 - 20% 15 - 20% 15 - 20% 1-3% 12 - 18% 10 - 25% 12 - 18% 12 - 18% 4-6% 55 - 60% 12 - 30% ALCOA0000481 oDhns-ManviHe fU*se?'c^ 4 Cnc*n*<ririj Ce iier P.0 Box 159 Man* N J. 0fce3w t?n> :-2-9rj. Mr. A. Goldberg Karen 2*., 1972 Attaconunt 1 -Page 2 "LOCKZ.'-JN" ASBESTOS PRODUCTS PRODUCT APPROXIMATE RANGE OF ASBESTOS CONTENTS IN PRODUCTS AS USED FRICTION MATERIALS Brake linings Clutch facings Heavy duty brake linings 15 70% 35 60% 70 75% PACKINGS & GASKETS Braided textiles (resin saturated) Millboard (polymeric bonded or encapsulated) Packings - sheeter type Packings - beater additive type 50 60% 85 95% 80 85% 55 80% PAPERS & FELTS Backing for sheet flooring (polymeric bonded) Cooling tower papers (inorganic bonded & coated) 85 88%* 80 90% Electrical papers & tapes (resin saturated) 65 75% Laminating papers (resin bonded) 50 65% Pipe line felts (bitumen saturated) 65 70% Protective metal sheets (metal bonded & enamel coated) 85 90% Roofing felts (bitumen saturated) 60 65% Underlayment felt (polymeric bonded) 85 88% PLASTICS Thermoplastics Thermosetting 20 40% 20 25% SEALING COMPOUNDS Caulking putties &sealants Radiator sealants & coolants TILE Asphalt tile Vinyl til\ Tile adhesives 15 45% 0 1% 15 25% 10 20% 3 10% Excludes vary.ng thicknesses of vinyl surface applied to the backing. The frl.er contend v\ the finished flooring product is much lower than these rang.*'- ALCOA0000482 Johns-Mariviile Research t F-wjineering Center P O fJo 150 Marwille, TJ J 0883S (201)722 9000 Mr. Arthur Goldberg March 24, 1972 Attachment 2 "NCN-LOCKED-IN" ASBESTOS PRODUCTS PRODUCT ACOUSTICAL PRODUCTS Dry spray type Foamed asbestos CALCIUM-SILICATE SHEETS Low density sheets (less than 50#/ft^) CEMENTS Gypsum joint cements Insulating cements INSULATIONS Low density calcium silicate binders Corrugated paper Low density magnesia binders High temperature blocks & bricks PAPERS & FELTS Commercial grades (unsaturated) Roofing felts (unsaturated) Gaskets (unsaturated or not encapsulated) Millboards (unsaturated or uncoated) STUCCO & PLASTER Dry mix cement stucco Dry mix decorative plaster TEXTILES (unsaturated or uncoated) Braided products Cloth Listing Wicks Yarn APPROXIMATE RANGE OF ASBESTOS CONTENTS IN PRODUCT AS USED 10 - 15% 85 - 90% 25 - 35% 2 - 4% 20 -100% 7 - 12% 85 - 95% 8 - 12% 8 - 12% 85 - 90% 85 - 90% 85 - 90% 85 - 90% 0-1% 0-2% 75 -100% 75 -100% 75 -loCl 75 -10 7 73 -100% ALCOA0000483