Document JvJwKOrXRZYgjvEEGJb7OZ36
August 9, 1978
G. Guzzardo, M.D./ Mr. J. L. Goodson
D. H. Glenn, M.D. R. W. Holland, Jr., M.D. F. Eulberg, R.hf. P. P. Konyha, M.D. A. A. Lang, M.D. F. M. Logsdon, M.D. Mr . K. G. Morlock F. Plechaty, R.N. R. J. Sexton, M.D./
B. P. Avashia, M.D. T. N. Spencer, Jr., M.D. R. Murphy, R.N. Mr . J. 0. Zimmerman
_ 519 - 515 - 514 - 513 - 312 - UCCI - 510 Tucker , Ga. - 380
- 512
511 - 526 - 330
The attachment received from Or. Lincoln is sent for your information. If you have any questions, please let me know.
EQH/ap
h13533
UNION CARBIDE CORPORATION Health, Safety and Environmental Affairs
270 Park Avenue - 22nd Floor New York, New York 10017
August 3, 1978
Memorandum to: UCC Physicians
Sponsor: Mr. J. B. Browning
Subject: Asbestos
Gentlemen:
A major governmental information campaign on the hazards of asbestos is under way. It will undoubtedly cause considerable anxiety among workers who have or think they may have been exposed to asbestos.
It is imperative that you respond to inquiries in a knowledgeable fashion. I know you are busy, but I would appreciate it if you would at least read the two-page background document attached. If you possibly can, I would also suggest that you read the Asbestos Standard and some extracted portions of the NICSH Criteria Document, copies of which have also been enclosed.
The really heavy exposures to asbestos occurred during World War II when ventilation was poor and respirator use was almost non-existent. It now has been 35 years, and no major epidemic of asbestosis or mesotheliomas has occurred. I believe the popularly projected occurrence of asbestosrelated diseases is grossly exaggerated and probably irresponsible.
We now have good industrial hygiene control of asbestos exposures in all our plants. I would urge you to check with the Assistant Corporate Medical Director responsible for your plant and division before you respond to any detailed inquiries about extent of past exposures or presumed medical risks. We will help you get the information you need if it is available.
The insulators' union, through the Insulators' Health Hazards Program, has been active in some locations requesting that chest x-rays be sent to Washington, D.C.,_to be interpreted by Dr. Irving J. Selikoff. If you should get such a request, we would appreciate learning about it.
Sincerely yours.
TAL:BA Attachments
cc: Mr. J. B. Browning Mr. T. W. Carmody Dr. H. H. Haynes
Thomas A. Lincoln, M.D.
A ;354C
BACKGROUND
On April 26, 1973 the Secretary for Health, Education, and Welfare,
Mr. Joseph Cali fane announced a governmental campaign to notify physicians.
past workers, and others at risk of the
associated with asbestos
exposure. He made a reasonably objective presentation of the situation that
emphasized past, extremely high exposures that occurred before the risk was
recognized and before regulations were enacted. Shipyard exposure during
World War II received particular attention.
This announcement came after several years of pressure by organized
labor and a variety of environmental activist groups. A summary of the steps
leading to the announcement and the information program planned by the
government are given in Attachment I.
The press coverage of this announcement lareglv iannred the "hioh
exposures well in the past" concept and impliea th
exposures including today's regulated uses. A good response to the inaccurate
coverage is provided in a statement prepared by the Johns-Manville Corporation
given here as Attachment II.
EXTENT OF THE MEDICAL PROBLEM
There is extensive, undisputed evidence that insulation workers in the
construction trade are at a very substantial excess risk of developing asbestosis
and mesothelioma. Those who smoke also are at very high risk from lung cancer.
Asbestos-containing insulation was widely used during World War II in ship .
2- construction and repair. Typically it takes 20, 30 or more years from initial exposure for asbestos-related diseases to appear so that the critical time period for wartime activities is now here.
Over the past several years substantial evidence has accumulated that very heavy exposures did occur in the shipyards. They are not only found in the insulation workers but also in other trades who were present in the confined spaces common on shipboard. So far the results have been mainly seen as asbestosis and in various lung changes in shipyard workers, although some excessive mesothelomias have been found at some locations.
The number of people who may be affected is pure speculation at this time. It is generally agreed that the risk of contracting an asbestosrelated disease depends directly on the intensity of exposure. The figures of 8-11 million workers exposed that are quoted apparently include all persons who have ever worked in a shipyard plus those from construction, mining and milling of asbestos and those involved with automotive brakes and brake repair. The insulation trade health experience is then applied to this total to arrive at the "five-seven million people will die of asbestosrelated disease" statements that frequently appear in the media. This assumes that all of the millions of workers have been exposed at the intensity of those in the insulation trade and will have the same health response. We believe that this is a gross exaggeration due to the assumptions used but there is really no scientific basis to speculate on a more correct estimate..
The medical problem arising from heavy asbestos exposures 20-30 years in the past thus appears to be real and substantial but the extent is clearly undefined.
A ; 354 1
S.I 1
<>71
11318
RULES AND REGULATIONS
[TJX 73-183]
tions for an Occupational Exposure exposure to asbestos fibers and the ap
PART 10--ARTICLES CONDITIONALLY FREE, SUBJECT TO A REDUCED RATE, ETC
Standard for Asbestos by the National Institute for Occupational Safety and Health (NIOSH). Public notice was given of the receipt of the recommendations
pearance of adverse biological manifes tations, such as asbestosls. lung cancers,
and mesothelioma, have given rise to controversy as to the validity of the
Free Withdrawal of Supplies and Equipment for Aircraft
and their availability for inspection and measuring techniques used and the relia coining. On or about February 25, 1972, bility of the relations attempted to be the Advisory Committee on Asbestos Dust established. Because of the long lapse
la accordance with section 309(d). submitted Its written recommendations of time between onset of exposure and
Tariff Act of 1930, as amended (19 UJS.C. to the Assistant Secretary of Labor for biological manifestations, we have now
1309(d)). the Department of Commerce Occupational Safety and Health.
evidence of the consequences of exposure,
has found and tinder date of April 25. - Pursuant to the notice of rule making, but we do not have. In general, accurate
1972, has advised the Treasury Depart a hearing was held on March 14 through measures of the levels of exposure oc
ment that Poland allows privileges to 17,1972, for the purpose of receiving oral curring 20 or 30 yean ago, which have
aircraft registered In the United States data, views, and arguments concerning given rise to these consequences. There
and engaged In foreign trade substan the proposed, standard. On or about are also controversies concerning the
tially reciprocal to those provided for In March 31, 1972, the presiding hearing ex relative toxicity of the various kinds of
sections 309 and 317 of the Tariff Act of aminer certified to the Assistant Secre asbestos, and varying hazards In dif
1930, as amended (19 U-S.C. 1309, 1317). tary of Labor for Occupations Safety ferent workplaces.
The same privileges are therefore hereby and Health the record of the proceeding. It is fair to say that the controversy
extended to aircraft registered In Poland The record Includes prehearing written has centered In the area between a two-
and engaged in foreign trade effective as comments, a transcript of the oral pres- fiber TWA concentration and five-fiber
of the date of such notification.
' entations made at the hearing, and nu TWA concentration, with variations on
Accordingly, paragraph (f) of S 1099, merous exhibits received during the the time needed for compliance. Many
customs regulations, is amended by the course of the hearing or within the pe employers support a five-fiber TWA.
insertion of Poland in appropriate al riod allowed after the - close of the Most medical opinion is divided between
phabetical order and the number of this hearing.
a two-fiber standard and a five-fiber
Treasury decision in the opposite col The proposed standard dealt with (1) standard. .
umn headed'"Treasury Decision(s) " in permissible concentrations of asbestos In view of the undisputed grave con
the list 'Of nations in that paragraph. fibers; (2) methods of compliance; (3) sequences from exposure to asbestos
(Scs. 309. 317. 324.43 Sat 3S0. M amended. 393. as amended. 759; 19 U.S.C. 1309, 1317, 1834)
warning signs; (4) monitoring; (5) med ical examinations; and (6) recordkeep ing. Each of these major proposals elic
fibers, it Is essential that the exposure be regulated now, on the basis of the best evidence available now, even though It
rsiiil
EawiK P. Ranis,
Acting Commissioner of Customs.
ited comments, arguments, objections, may not be as good as scientifically de
and counterproposals. They all have been sirable. An asbestos standard can be re
examined and considered.
evaluated In the light of the results of
Approved: May 25,1972.
1. Acceptable concentrations of asbes ongoing studies, and future studies, but
Extceks T. Rossdes, Assistant Secretary of the Treasury.
tos dust. The proposed standard would limit occupational exposure to 8-hour
time-weighted average (TWA) airborne concentrations of asbestos dust not ex
cannot wait lor them. Lives of employees areatstake. -
It is concluded that there should be one minimum standard of exposure to
]PH Doc.73-6578 Filed 8-6-72:8:50 am] ceeding five fibers longer than five asbestos applicable to all workplaces ex
c/ TI
micrometers per milliliter. Concentra posed to any kind, or mixture of kinds, tions above five fibers but not to exceed of asbestos. Reasons of practical ad
Title 29--LABOR
10 fibers (celling concentration) would ministration preclude a variety of stand be permitted up to 15 minutes in an hour, ards for different kinds of asbestos and
Chapter XVII--Occupational Safety and Health Administration, Depart ment of Labor
but for not more than 5 hours In any one 8-hour day.
NIOSH In effect has recommended that the five-fiber TWA and 10-flber
of workplaces. Also, while the evidence tends to show that croddollte, for in stance. is more harmful than chrysotUe.
the evidence Is not sufficient to establish
PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS
peak concentrations be permitted only
for 2 yean; thereafter, TWA concentra tions should be not more than 2 fibers
separate standards for varieties of
asbestos. Because there must be one standard
Standard for Exposure to Asbestos Dust
per cubic centimeter (cm.*) of air, and governing exposure to all varieties of peak concentrations should not exceed 10 asbestos, and In workplaces apparently fibers/cm.*, with no time restriction. more hazardous than others; because
On December 7, 1971, an emergency Numerous objections and counterpro some present employees with regular ex
temporary standard concerning exposure posals have been made, with regard to posure to asbevtos have probably al
to asbestos fibers was published in the both the limits of asbestos fiber concen ready accumulated great doses of asbes
Fzdesax. Racism (36 FJL 23207). In ac trations and the time periods to comply tos fibers, due to higher levels of ex
cordance with section 6(c) (3) of the WH- with them. Some, for example, have rec posure In the past; because it appears
liams-Steiger Oecuptaional Safety and ommended return to a 12-fiber standard that levels of exposure which may be
Health Act of 1970, a notice of proposed of on earlier day; l.e,, a level adopted safe with regard to asbestosls are not
rulemaking regarding a permanent under the Walsh-Healey Public Con safe with regard to mesothelioma; be
standard for exposure to asbestos fibers tracts Act In 1969. Others have recom cause the statute requires the protection
was published In the Fcnnuu. Racism on mended a two-fiber standard to become of every employee, even of one who may
January 12. 1972 (37 F.R. 466). The no effective In 6 months, then a one-fiber have regular exposure to asbestos during
tice Invited interested persons to submit standard for 2 years, and finally a zero- a working life which may reach, or even
both orally and in writing, data, views, fiber standard after 3 years. These' rec exceed, 40 years; and because of several
and arguments concerning the proposal. ommendations give a fair indication of other considerations which have been
On or about January 24,1972, the Ad the wide spread of the counterproposals. urged and are reflected In the record of
visory Committee on Asbestos Dust was No one has disputed that exposure to the proceeding, the conflict In the medi
established and requested to make writ asbestos of high enough intensity and cal evidence is resolved In favor of the
ten recommendations with regard to the long enough duration is causally related health of employees. As of July 1, 1976,
proposed standard on asbestos. On or to asbestosls and cancers. The dispute Is TWA concentrations of asbestos fibers
about February 1, 1972, the Department as to the determination of a specific level longer than S micrometers will not be
of Health. Education, and Welfare trans below which exposure is safe. Various allowed to exceed two flbers/cc.. with a
mitted to the Secretary of Labor a cri studies attempting to establish quantita filing value of 10 flbers/cc. The current
teria document containing Recommenda tive relations between specific levels of TWA concentrations of five fibers, and
FEDEIAl KEGISTEt, VOL. 3T. NO. 110--WEDNESDAY,
;"
3542
RULES AND REGULATIONS
11319
ceiling concentrations of 10 flte'rs/cc, fibers, so that these would not be released 6. Records. The standard, as proposed
will be permitted until July 1. 1976, dur In the normal use of the products, should and as adopted, requires maintenance of
ing what will be a transitional period not be required to be labeled: and (2) records of monitoring and of medical
deemed necessary to allow employers to words such as "danger" and "cancer" axe examinations. Most of the controversy in
make the needed changes lor coming unwarrantedJy alarming.
this area has revolved around the ques
into compliance with the more stringent Both contentions have merit, and the tion whether an employer should be al
standard.
standard has been changed accordingly. lowed to have access to the results of
The record shows that the many work 4. Monitoring. The proposed standard the required medical examinations. The
operations subject to the single asbestos would have required personal monitor apprehension of those who have argued
standard (textile, manufacturing, indus ing and environmental monitoring. against employer access is based on the
trial, and marine installation, etc.) will Many issues have been raised concerning expectation that some employers will use
meet varying degrees ot difficulty in the availability and reliability of meas the medical examinations as a means of
complying with the standard. In some uring instruments, frequency of moni screening employment applicants, and
plants, extensive redesign and reloca toring, and conditions in which monitor worse, as grounds for discharging current
tion of equipment may be needed. It ap ing should be required. The adopted employees, who show signs of being af
pears, however, the delay in the effective standard takes the objections into con fected by exposure to asbestos. Since the
date of the two-fiber standard will pro sideration. It requires periodic monitor purpose of the medical examinations is
vide all employers a reasonable time to ing at intervals no longer than 6 months, to monitor the health of employees ex
comply. At the same time, so long as the thus allowing considerable time and dis posed to the hazards of abestos, em
ceiling limit is complied with, no harm cretion. and prescribes the use of the ployees cannot in reason be granted the
is reasonably expected to result from ex membrane filter method, which is an ac privilege of refusing to disclose to their
posures during the transitional period. ceptable method for determination of employers results of occupational expo
2. Methods of compliance. It has been pointed out by many persons, that pro tection against asbestos fibers is best obtained by controlling the generation of fibers first, and secondly, by controlling the dispersion of released fibers Into the ambient air of the workplaces. Therefore, the standard requires feasible techno logical controls and appropriate work practices as the primary means of com pliance. Rotation of employees as a way of meeting the TWA concentration re quirement Is allowed only in stated ex ceptional circumstances, because, as a
asbestos fibers. It has also been recommended that
employees or their representatives should have an opportunity to observe the monitoring. The recommendation has been accepted.
5. Medical examinations. This pro posed standard would only require an appropriate medical examination on a
periodic basis. The generality of the pro
posal has attracted many objections and also many helpful comments. The recom mendations of NIOSH and of the Advi
sory Committee on Asbestos Dust were
sure. It does not make sense to require employers to provide medical examina tions if they cannot know and use the results of the examinations. For these reasons the standard provides that em ployers may have a restricted access to some medical Information.
On the' other hand, there is no inten tion to allow employers to abuse medical
information obtained pursuant to the Act, to the detriment of employees. Therefore, the administration of the medical records requirement will be closely watched, and, in cases of abuse,
general rule. It would be difficult to im plement. Personal protective equipment, such as TTKmratnw cannnc be relied
upon because, among other reasons, they mav be so uncomfortable as to be burdensome, except fonhort periods of
much more specific with respect to both, frequency and type of medical examina tions to be required. The comments vary
as to the class of employees to be ex amined and as to the frequency of the examinations.
appropriate action will be considered.
The Issues discussed above are believed to be the major ones. Numerous other is sues have been raised in the rulemaking proceedings. Some have been referred to incidentally. Many recommendations, for
time. Therefore, it is expected that res The adopted standard requires medical -.nstance, about work practices, are so
pirators and shift rotation will be used examinations both at the beginning and obviously meritorious that their adop
during the period necessary to Install en the termination of employments exposed tion needs no exposition here. Other
gineering controls and to train employ to concentrations of asbestos fibers, and recommendations and many objections ees in sound work practices, but, after also requires annual medical examina have not been adopted for a variety of
technological compliance has been achieved, their use must be limited to special work situations and emergencies. Where both are practicable, shift rota
tions of every employee exposed to air borne concentrations of asbestos. It has been pointed out that in certain indus tries. such as construction, an employee
reasons which should be manifest. Sev
eral. for instance, have recommended, the use of respirators only pursuant to a variance, or in cases of emergency and
tion is required. .
--
3. Labeling. The proposed standard
stopped short of requiring labeling as
bestos and asbestos-containing products.
The proposed standard would have re
may work for several employers during the same year. Accordingly, the standard does not require either preemployment,
or termination, or periodic examlnaton of any employee who has been examined
occasional short-term exposures. The recommendation with respect to vari ances undoubtedly has many merits, but Is considered administratively im
quired cmly warning signs at locations in accordance with the standard within practical.
where asbestos hazards are present. the past year.
Accordingly, after consideration of the
However, labeling, rather than warning One question which has been raised whole record of the proceeding, and
signs, has proved to be a point of con troversy. Both NIOSH and the Advisory Committee on Asbestos Dust recom
mended labels for asbestos products and containers, and these recommendations
goes to whether the employer or the em ployee should be allowed to choose the examining physician. The standard
gives the option to the employer. Since some employers already have a medical
pursuant to sections 6 <b) and (c> and ' 8(c) of the Will liuns-Stelger Occupa tional Safety and Health Act of 1970 ( 84 Stat 1593, 1596, 1599; 29 US.C. 655,
became very controversial la the course examination program in operation, and. 657), 29 CTO 1910.4, and to Secretary of
of the proceeding. Many counterpro also, have medical departments with Labor's Order No. 12-71 (36 FJt. 8754),
proposals have been made as to the languagt of the warning as well as to the products to be subject to the labeling requirements. Employers, in general,
strongly contend that (1) finished prod
some expertise in the diagnosis of abestos-related diseases. It seems more
reasonable to permit them to utilize the present programs and expertise, than to permit an employee to choose a private
Part 1910 of Title 29 of the Code of Fed eral Regulations is amended as set forth below.
(1) Section 1910.93 Is amended by re-
ucts which effectively entrap asbestos general practitioner.
' vising Table 0-2 to read as follows:.
A'3543
FEDflAL KEOISm, VOL 37, HO. 110--WEDNESDAY, JUNf 7, 1977
11320
RULES AND REGULATIONS
8 1910.93 Air conUminsnU.
to which any employee may be exposed (d) Personal protective equipment-- shall not exceed two fibers, longer than (1)Compliance with the exposure limits
Tut* o-t-itsxnui Dm
5 micrometers, per cubic centimeter of prescribed by paragraph (b> of this sec air, as determined by the method pre tion may not be achieved by the use of
SaUUooa
Wpprf UsftP scribed in paragraph (e) of this section. respirators or shift rotation of em (3) Ceiling concentration. So em ployees, except:
BQka:
ployee shall be exposed at any time to (1) During the time period necessary
Crystallise: QoarU <resptnble).200f
QoarL (total dost)
%S10rf-5
CrtstoballU: Um H tbe Taint calculated Cram the
qcuoaunrttso. r mas tenmlae tor
Tridymite: UH the raise
caicokted from the farmake (or quarts. Amorphous, lodudlof Dstural diatomaoeous earthly.......
30
lOmg/M*
%SiOrf2
30mg/M* %SiOH-2
XtmiflP %ao*
airborne concentrations of asbestos
fibers in excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, as determined by the method pre
scribed In paragraph (e) of this section. (c) Methods of compliance--(1) En
gineering methods. (1) Engineering con trols. Engineering controls, such as, but
not limited to, isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits
prescribed in paragraph (b) of this section.
to install the engineering controls and
to Institute the work practices required by paragraph (c) of this section;
(II) In work situations In which the methods prescribed in paragraph (c) of this section are either technically not feasible or feasible to an extent insuffi cient to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph (b) of this section; or
(ill) In emergencies.
Sfficates (loo than 1% crj> tellinc silica): mw
Soapstone_____ ______
Talc........ .......... Portland omnt _... T.. , Graphite (natural).................. Coal dust (respirable fraction
jo 2D
2D A0 15
(11) Local exhaust ventilation, (a)
Local exhaust ventilation and dust col lection systems shall be designed, con structed. Installed, and maintained in
accordance with the American National Standard Fundamentals Governing the
. (iv) Where both respirators and per sonnel rotation are allowed by subdivi sions (i), (11), or (lii) of this subpara graph. and both are practicable, person nel rotation shall be preferred and used.
(2) Where a respirator Is permitted by
lea than 6% SlO)-----........................ For more than 5% GiOt.............
Inert or Kuisanee Dust: Respirable traction.__ Total
15 60
2.4rng/Ml or
lOmg/M1
%SK>rt'2
Scng/M1 Umg/M*
Not*: CooTasioafrcton--
mppclX35.3--million particles per coble meter
' -- particles per c-c.
I MQUons of partieks per cubic foot oi air, based on
lmpinger samples counted by Ugbt-fleid technics.
1 The percentage of crystalline slice in the formula
b tUe amount datennioad from air-borne samples,
except In those tmtanees in which other methods hare
been shown to be applicable.
j As determined by tbe membrane Alter method at
430 X phase cootrust
Both concentration and percent quartz for tbe
application of this limit are to be determined from
tbe fraction
a see-selector with the following
characteristics
Aerodynamic diameter (unit density sphere) .
Percent passing selector
Design and Operation of Local Exhaust Systems. ANSI Z9.2-1971, which is in corporated by reference herein.
(b) See $ 1910.6 concerning the avail ability of ANSI Z9.2-1971, and the maintenance of a historic file In connec tion therewith. Hie address of the Amer ican National Standards Institute Is given in 11910.100.
(iii) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of tbe exposure limits pre scribed in paragraph <b) of this section, such as. but not limited to, saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems In accordance with subdivision (li> of this subparagraph.
<2) Work practices--<i> Wet methods. Insofar as' practicable, asbestos shall be
subparagraph (X) of this paragraph, it
shall be selected from among those ap proved by the Bureau of Mines, Depart ment of the Interior, or the National In stitute for Occunational Safety and Health, Department of Health, Educa tion. and Welfare, und-r the provisions of 30 CFR Part 11 (37 FB. 6244. Mar. 25. 1972), and shall be used in accordance
with subdivisions (1), (ii), (ill), and (lv) of this subparagraph.
(1) Air purifying respirators. A reusa
ble or single use air purifying respirator, or a respirator described In subdivision (U) or (ill) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in
paragraph (b) of this section, when the ceiling or the 8-hour time-weighted aver age airborne concentrations of asbestos fibers are reasonably expected to exceed
2 90 2.5 75 15 50 5.0 25 10 0
Tbe measurement* under thb note refer to the use of an AC Instrument. U tbe respirable fraction of ooal dust b determined with a MR tbe firore corresponding to that of 2.4 Mg/M1 In the table for coal dust k U Mg/M1.
handled, mixed, applied, removed, cut, scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers in excess of the ex posure limits prescribed in paragraph (b) of this section, unless the usefulness of the product would be diminished
thereby.
no more than 10 times those limits.
(ID Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers in the
- 2. A new 11910.93a Is added to Part 1910, reading as follows:
1910.93. Asbestos
(U) Particular products and opera tions. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed
respirator below the exposure limits pre scribed In pararvaph (b> of this section, when the celling or the 8-hour time-
weighted average concentrations of
(a) Definitions. For the purpose of from bags, cartons, or other containers asbestos fibers- are reasonably expected
this section, (1) "Asbestos" Includes in which they are shipped, without being to exceed 10 times, but not 100 times,
chrysotlle. amoslte, croddolite, tremo- either wetted, or enclosed, or ventilated those limits.
lite, anthophylllte, and actlnolite.
(2) "Asbestos fibers" means asbestos fibers longer than 5 micrometers.
(b) Permissible exposure to airborne
so as to prevent effectively the release of airborne asbestos fibers In excess of the limits prescribed In paragraph (b) of this section.
(III) Type "C" supplied-air respirators,
continuous flow or pressure-demand
class. A type "C" continuous flow or pres sure-demand. supplied-aLr respirator
concentrations of asbestos fibers--(1)
(Ui) Spraying, demolition, or removal. shall be used to reduce the concentra
Standard effective July 7. 1972. The Employees engaged in the spraying of tions of airborne asbestos fibers in the
8-hour time-weighted average airborne asbestos, the removal, or demolition of respirator below the exposure limits pre
concentrations of asbestos fibers to pipes, structures, or equipment covered scribed In paragraph (b) of this section,
which any employee may be exposed or insulated with asbestos, and In the when the ceiling or the 8-hour time-
shall not exceed five fibers, longer than removal or demolition of asbestos in weighted average airborne concentra
5 micrometers, per cubic centimeter of sulation or coverings shall be provided tions of asbestos fibers are reasonably
air, as determined by the method pre scribed In paragraph (e) of this section.
(2) Standard effective July 1, 1976.
Tbe 8-hour time-weighted average air
with respiratory equipment In accord ance with paragraph (d)(2) (111) of this section and with special clothing in ac cordance with paragraph (d) (3) of this
expected to exceed 100 times those limits. (iv) Establishment of a respirator pro
gram. (a) The employer shall establish
borne concentrations of asbestos fibers section.
,
a respirator program in accordance with
A 1 3 5 4:4ix-Xi
FEDERAL REGISTER, VOL 37, NO. no--WEDNESOAY, JUNE 7. 1972
RULES AND REGULATIONS
11321
the requirements of the American Na where asbestos fibers are released to be subparagraph shall conform to the re
tional Standards Practices for Respira monitored in such a way as to determine quirements of 20" x 14" vertical format
tory Protection, ANSI Z88.2-1969, which whether every employee's exposure to signs specified in 11910.145(d)(4), and
is incorporated by reference herein.
asbestos fibers Is below the limits pre to this subdivision. The signs shall dis
b. See 3 1910.6 concerning the avail scribed in paragraph, (b) of this sec play the following legend in the lower
ability of ANSI Z88.2-1969 and the main tion. If the limits are exceeded, the em panel, with letter sizes and styles of a
tenance of an historic file in connection ployer shall immediately undertake a visibility at least equal to that specified
therewith. The address of the American compliance program in accordance with in this subdivision.
National Standards Institute is given in
1910.100. (c) No employee shall be assigned to
tasks requiring the use of . respirators if,
paragraph (c) of this section. (2) Personal monitoring--(i) Sam
ples shall be collected from within the breathing zone of the employees, on
Legend Asbestos
Notation
1" Sana Serif. Oothle or Block.
based upon his most recent examination, membrane filters of 0.8 micrometer po- Dust Hazard__________ ,, >4" .Sana Serif.
an examining physician determines that rossity mounted in an open-face filter
Gothic or
the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or other employees will be Impaired by hi* use of a respirator. Such employee shall
holder. Samples shall be taken for the determination of the 8-hour timeweighted average airborne concentra
tions and of the ceiling concentrations of
asbestos fibers.
Avoid Breathing Dust___ Wear Assigned Protective
Equipment. Do Not Remain In Area
Unless Tour Work Re
Block. *4" Gothic. V4" Gothic.
14'* Gothic.
be rotated to another job or given the <li) Sampling frequency and patterns. quires It.
opportunity to transfer to a different po After the initial determinations required Breathing Asbestoa Dust 14 point Gothic.
sition whose duties be Is able to perform by subparagraph (1) of this paragraph, May Be Hazardous To
with the same employer, in the same geo samples shall be of such frequency and Your Health.
graphical area and with the same senior ity. status, and rate of pay he bad lust prior to such transfer, if such a different
position is available.
pattern as to represent with reasonable ' Spacing between lines shall be at least accuracy the levels of exposure of em equal to the height of the upper of any ployees. In no case shall the sampling be two lines. done at Intervals greater than 6 months (2) Caution labels--(i) Labeling. Cau
(3) Special clothing: The employer
shall provide, and require the use of, spe
cial clothing, such as coveralls or similar
whole body clothing, head coverings,
gloves, and foot coverings for any em
ployee exposed to airborne concentra
tions of asbestos fibers, which exceed the
ceiling level prescribed in paragraph <b>
of this section.
(4) Change rooms: (i) At any fixed
place of employment exposed to airborne
concentrations of asbestos fibers in ex
cess of the exposure limits prescribed in
paragraph <b> of this section, the em
ployer
provide change rooms for
employees working regularly at the place.
(ii> Clothes lockers: The employer
shall provide two separate lockers or con
tainers for each employee, so separated
or isolated as to prevent contamination
for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph (b)
of this section. (3) Environmental monitoring--(1)
samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of
asbestos fibers which may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8-
hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers.
(ii> Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph,
tion labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that
no label Is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use,
handling, storage, disposal, processing, or transportation, no airborne concentra
tions of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released.
(ii> Label specifications. The caution
labels required by subdivision (i) of this subparagraph shall be printed in letters of sufficient size and contrast as to be
readily visible and legible. The label shall state:
Cactiom
of the employee's* street clothes from his samples shall be of such frequency and
work clothes.
pattern as to represent with reasonable
(lil) Laundering:' (a) Laundering of accuracy the levels of exposure of the
Contains Asbestoa Fibers Avoid Creating Duse
asbestos contaminated clothing shall be employees. In no case shall sampling be done so as to prevent the release of air at Intervals greater than 6 months for
Breathing Asbestoa Dust May Cause Serious Bodily Harm
borne asbestos fibers in excess of the ex employees whose exposures to asbestos <h) Housekeeping--(1) Cleaning. All
posure limits prescribed in paragraph (b) may reasonably be foreseen to exceed external surfaces in any place of employ
of this section.
the exposure limits prescribed in para ment shall be maintained free of accu
<b) Any employer who gives asbestos- graph (b) of this section.
mulations of asbestos fibers if, with their
contaminated clothing to another person (4) Employee observation of monitor dispersion, there would be an excessive
for laundering shall Inform such person ing. Affected employees, or their rep concentration.
of the requirement in (a) of this subdi
vision to effectively prevent the release of airborne asbestos fibers In excess of
the exposure limits prescribed in para
resentatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof.
(2) Waste disposal Asbestos waste, scrap, debris, bags, containers, equip ment. and asbestos-contaminated cloth ing. consigned for disposal, which may
graph <b) of this section.
<g> Caution signs and labels. (1) Cau produce in any reasonably foreseeable
(c) Contaminated clothing shall be tion signs. (1) Posting. Caution signs eue, handling, storage, processing, dis
transported In sealed Impermeable bags, shall be provided and displayed at each posal. or transportation airborne concen
or other closed. Impermeable containers, location where airborne concentrations trations of asbestos fibers In excess of the
and labeled in accordance with para of asbestos fibers may be In excess of the exposure limits prescribed in paragraph,
graph (g) of this section.
exposure limits prescribed In paragraph (b) of this section shall be collected and
(e) Method of measurement. All de (b) of this section. Signs shall be posted disposed of in sealed impermeable bags,
terminations of airborne concentrations at such a distance from such a location or other dosed, impermeable containers.
of asbestos fibers shall be made by the so that an employee may read the signs (i) Recordkeeping--(1) Exposure rec
membrane filter method at 400-430 X and take necessary protective steps be ords. Every employer shall maintain rec
(magnification) (4 millimeter objective)
with phase contrast illumination. (f) Monitoring---(1) Initial determi
fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive
concentrations of airborne asbestos
ords at any personal or environmental monitoring required by this section. Rec ords shall be maintained for a period of at least 3 yean and shall be made avail
nations. Within 6 months of the publi fibers.
able upon request to the Assistant Secre
cation of thiSuSc*ioi}.3?very employer, . . . til)...Sign specifications. The warning tary of Labor for Occupational Safety
shall cause every place of employment signs requhed^y
of this and Health, the Director of the National
FHJEKAl IEOISTH, VOL 37, NO. 1 lO--WIONUOAV, JUN* 7, 1972
11322
RULES AND REGULATIONS
Institute for Occupational Safety and tions. Records shall be retained by Instruction section has been revised ac
Health, and to authorized represellta^ ' fives of either.
(21 Employee access. Every employee and former employee shall have reason*
employers for at least 20 years.
(11) Access. The contents of the rec ords of the medical examinations required by this paragraph shall be made
cordingly. Minor editorial changes have also been made.
1. Section 9-1.101 Scope of subpart, is revised to read as follows:
able access to any record required to be maintained by subparagraph (1) of this
available, for inspection and copying, to the Assistant Secretary of Labor for
9-1.101
Scope ot rubpart.
paragraph, which indicates the em Occupational Safety and Health, the This subpart describes the Atomic
ployee's own exposure to asbestos fibers. (3) Employee notification. Any em
ployee found to have been exposed at any time to airborne concentrations of asbes tos fibers in excess of the limits pre scribed in paragraph (b) of this section shall be notified in writing of the expo sure as soon as practicable but not later
Director of NIOSH, to authorized physi cians and medical consultants of either of them, and, upon the request of an em ployee or former employee, to his physi cian. Any physician who conducts a medical examination required by this paragraph shall furnish to the employer of the examined employee all the Infor
Energy Commission Procurement Regu lations and the AECPR Temporary Reg
ulations. It also describes exclusions from the AECPR as contained in the AEC Procurement Instructions.
2. Section 9-1.102 Establishment ot AEC Procurement Regulations, is revised to read as follows:
than 5 days of the finding. The employee shall also be. timely notified of the cor
rective action being fatten. (]) Medical examinations--(1) Gen
mation specifically required by this
paragraph, and any other medical In formation related to occupational ex posure to asbestos fibers.
9--1.102 Establishment of the AEC Procurement Regulations and. the AECPR Temporary Regulations.
eral. The employer shall provide or make
9-1.102-1 AEC Procurement Regula
available at his cast, medical examina 3. A new { 1910.19 is added to Subpart
tions,
tions relative to exposure to asbestos re B of Part 1910, reading as follows:
(a) The AEC Procurement Regula
quired by this paragraph. (2) Preplacement. The employer shall
1910.19
Asbestoa dost.
provide or make available to each of his Section 1910.93a shall apply to the ex
employees, within 30 calendar days fol posure of every employee to asbestos
lowing his first employment in an dust In every employment and place
occupation exposed to airborne con- of employment covered by {1910.12,
. centrations of asbestos fibers, a compre- i 1910.13, ] 1910.14. 5 1910.15. or ! 1910.16,
'hensive medical examination, which shall In lieu of any different standard on ex
Include, as a minimum, a chest roent posure to asbestos dust which would
genogram (posterior-anterior 14 x 17 otherwise be applicable by virtue of any
Inches), a history to elicit symptom of those sections.
atology of respiratory disease,., and. Effective date. Paragraph (b)(2) of
pulmonary function tests to include f 1910.93a shall become effective July 1,
forced vital capacity (FVC) and forced 1976. All other provisions of Si 1919.93a,
expiratory volume at 1 second (FEVL<). 1910.93, and 1910.19 shall become effec
tions (AECPR) are hereby established.
(b) These regulations Implement and
supplement the Federal Procurement
Regulations (FPR) and are a part of
the Federal Procurement Regulations
System.
____
(c) The effective date of FPR Issu
ances throughout AEC will be the date
Indicated in the respective issuances un
less otherwise provided In the AEC Pro
curement Regulations.
____
(d) The effective date of AECPR Is
suances throughout AEC will be the date
indicated in the respective issuances.
(3) Annual examinations. On or be tive July 7,1972. The current emergency 9-1.102-2 AECPR Temporary Regu
fore January 31. 1973, and at least an- temporary standard remains In effect
lations,
nually thereafter, every employer shall until July 7, 1972.
(a) The AECPR Temporary Regula
provide, or make available, comprehen sive medical examinations to each of his
(Secs. 6. 8. 84 SUt. 1883. 1898; 29 US.C. 888. 887; 29 CFR 1910.4; Secretary ot Labor's
tions are hereby established. (b) These regulations Implement and
employees engaged in occupations ex Order No. 13-71, 38 P.R. 8784)
supplement the Federal Procurement
posed to airborne concentrations of as bestos fibers. Such ""! examination shall Include, as a miniTwnm, a chest
Signed at Washington, D.C., this 2d day of June 1972.
Regulations Temporary Regulations. They also contain policies and proce
dures Initiated by the AEC which are
' roentgenogram (posterior-anterior 14 x.
G. C. Guxxthzx,
expected to be effective for a period of
17 Inches), a history to elicit symptom
Assistant Secretary of tabor. 6 months or less.
____
atology of respiratory disease, and pulmonary function tests to Include
(FB Doc.72-8874 filed 8-8-72:8:48 am]
(o) The effective date of the FPR Temporary Regulations issuances
forced vital capacity (FVC) and forced
throughout AEC will be the date indi
expiratory volume at 1 second (FEVj..).
(4) Termination of employment. The
employer shall provide, or make avail able, within 30 calendar days before or
after the termination of employment of any employee engaged In an occupation
exposed to airborne concentrations of asbestos fibers, a comprehensive medical examination which shall Include, as a minimum, a chest roentgenogram (pos-~
terior-anterlor 14 x 17 Inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests to Include forced vital capacity (FVC) and forced expiratory volume at 1 second
Title 41--PUBLIC CONTRACTS AND PROPERTY MANAGEMENT
Chapter 9--Atomic Energy Commission
PART 9-1--GENERAL
Subpart 9--1.1--Procurement Regulations
Miscellaneous Akznbkznts The changes made In AECPR Subpart
cated In the respective Issuances unless
otherwise provided in the AECPR Tem
porary Regulations."
____
(d> The effective date of the AECPR
Temporary Regulations Issuances
throughout AEC will be the date indi
cated in the respective issuances.
(e) The AECPR Temporary Regula
tions are a part of the AEC Procurement
Regulations and the Federal Procure
ment Regulations System. All references
to the AEC Procurement Regulations or
AECPR In H 9-1.103 through 9-1.109 of
this subpart shall be deemed to include
the AECPR temporary regulations.
(FEVt.),
(5) Recent examinations. No medical examination is required of any em ployee, If adequate records show that
9-1.1, Procurement Regulations, have been made In order to establish the AECPR Temporary Regulations, which
are a part of the AEC Procurement Reg
3. Section 9-1.103 Authority, is revised to read as follows:
S 9-1,103 Authority.
the employee has been examined In ac ulations and the Federal Procurement The AEC Procurement Regulations are
cordance with this paragraph within the Regulations System. The AECPR Tem prescribed by the General Manager, As
past 1-year period.
porary Regulations Implement and sup sistant General Manager for Administra
(6) Medical records--(1) Mainte
nance. Employers of employees examined pursuant to this paragraph shall cause
Wfto be maintained complete and accurate records of all such medical examlna-
plement the FPR Temporary Regula tions. They also contain policies and procedures Initiated by the AEC which are to be effective for a period of 6
months or less. The AEC Procurement
tion, or the Director, Division of Con tracts of the AEC, pursuant to the au thority of the Atomic Energy Act of 1954, and the Federal Property and Adminis
trative Services Act of 1949.
FEDEtAl KEGIS7H, VOL 37, NO. 110--WEDNESDAY, JUNE 7, 1973
NIOSH REVISED RECOMMENDED ASBESTOS STANDARD
III. EFFECTS ON HUMAN
Nonmalignant Respiratory Diseases (a) Historical Studies The use of asbestos dates back thousands of years; however,
the modern industry dates from about 1880, when it was used to make heat and acid resistant fabrics, (Hendry, 1965; Hueper, 1966). With the increasing use of asbestos materials, reports of asbestosrelated disease emerged.
The first record of a case of asbestosis was reported in England by Montague Murray in 1906. Hoffman (1918) reported that it was the practice of American and Canadian insurance com panies not to insure asbestos workers due to unhealthful conditions in that industry. Pancoast et al (1917) commented on x-ray changes resembling pneumoconiosis in 15 individuals exposed to asbestos. The first complete description of asbestosis and of the "curious bodies" seen in lung tissue appeared when Cooke (1927) reported on a case of asbestosis, and McDonald (1927) reported on the same and another case. Each author gave reasons for believing that these "curious bodies" originated from asbestos fibers that had reached the lungs. Mills (1930) reported the first case of asbestosis in the United States, and in the same year, Lynch and Smith (1930) reported on "asbestosis bodies"* found in the sputum of asbestos workers. Early studies led many investigators to conclude that people exposed to asbestos dust developed the disease "asbestosis" if the dust concentration was high or their exposure was long (Merewether and Price, 1930; Merewether, 1934;
*"Ferruginous bodies" is a more descriptive term, as other inhaled fibers, eg, fibrous glass, may also become iron coated.
o 547
2
Fulton et al 1935; Dreessen et al, 1938). (b) Epidemiologic Studies Harries (1968) reported that although first impressions
would lead one to believe that only workers continuously exposed to asbestos are at risk of developing asbestosis, further consid eration of the industry and processes should have suggested that many other workers were also at risk. For example, some trades worked in confined spaces where asbestos was used. Work in ship board trades was accepted by the Pneumoconiosis Panel of the United Kingdom as associated with asbestosis.
Murphy et al (1971a) found that asbestosis was 11 times more common among pipe insulators involved in new ship construction than among a control group. Asbestosis first appeared 13 years after exposure or at about 60 mppcf-years. The prevalence was 38% after 20 years. They also reported a case of extensive pleural calcification in a worker whose only known asbestos exposure was during sanding asphalt and vinyl tile floors (Murphy et al, 1971b).
Lorimer et al (1976), in a study of brake repair and mainten ance workers exposed to asbestos, found that 25% of the workers showed evidence of x-ray abnormalities consistent with asbestosis. One quarter also had restrictive pulmonary function test findings.
Meurman et al (1973) found a three-fold risk of dyspnea and a two-fold risk of cough for asbestos workers as compared with controls, after adjusting for smoking.
Weill et al (1975) reported a decreased lung function in relation to increasing cumulative dust exposure in a group of asbestos cement manufacturing workers. Ayer and Burg (1976) reported a decrease in pulmonary function in asbestos textile workers with less than ten years of exposure.
cl
7* .5= 48
3
(c) Description of Asbestosis Asbestosis is a chronic lung disease due to the inhalation of asbestos fibers and is characterized by diffuse interstitial fibrosis, frequently associated with pleural fibrosis (thicken ing) or pleural calcification. The characteristic x-ray changes of asbestosis are small irregular opacities in the lower and middle lung fields, often accompanied by pleural thickening and pleural calcifications. The pulmonary fibrotic changes develop slowly over the years-- often progressively even without further exposure--and their radiographic detection is a direct correlate of their extent and pro fusion. In some cases, minor fibrosis with considerable respiratory impairment and disability can be present without equivalent x-ray changes. Conversely, extensive radiographic findings may be present with little functional impairment. Commonly found in asbestosis are pulmonary rales, dyspnea, finger clubbing and cyanosis, but any of all can be absent in any one case. Pulmonary hypertension is frequently associated with advanced asbestosis and the resultant cor pulmonale (right-sided heart failure) may be the cause of death.
Carcinogenicity (a) Occupational Exposure (1) Historical Studies In 1935, 55 years after the start of large-scale usage
of asbestos in industry, suspicion of an association between asbestosis and lung cancer was reported by Lynch and Smith (1935) in the USA and by Gloyne (1935) in the UK. About 10 years later, case reports of pleural and peritoneal tumors associated with asbestos appeared (Wedler, 1943, a,b; Wyers, 1946). Epidemio logic evidence from Doll (1955) showed a ten-fold excess risk of lung cancers in those UK asbestos textile workers who had been employed before 1930, before regulations produced improved dust
4
conditions in factories. Similar findings were reported in the USA in 1961. Mesotheliomas were also detected but this fact was not published until later (Mancuso and Coulter, 1963; Selikoff et al, 1964). Possible variations in risk with different types of fiber were rarely considered in the early reports. Since 1964, following the recommendations of the UICC Working Group on Asbestos Cancers (UICC 1965) for new studies, there has been an expansion of epidemiologic studies in many parts of the world.
(2) Epidemiologic Studies (A) Lung Cancer, Pleural and Peritoneal Mesotheliomas (i) Mixed Types of Fiber In most industrial processes different types
of fiber are mixed, so that pure exposures to a single asbestos type are rare. Mortality studies of defined populations of asbestos-manufacturing, insulating, and shipyard workers have provided the most concrete evidence concerning the association between bronchial cancer, pleural, and peritoneal mesotheliomas and exposure to asbestos. Reports have come from several countries: (UK) Newhouse, 1969; (FRG) Bohlig et al, 1970; (USA) Selikoff et al,. 1970; (UK) Elmes and Simpson 1971; (The Netherlands) Stumphius, 1971; (Italy) Rubino et al, 1972.
A seven-fold excess of lung cancer was found in a group of insulation workers whose exposures had been to chrysotile and amosite but not crocidolite (Selikoff et al, 1971). Enterline and Henderson (1973) reported a 4.4 times increased risk of respiratory cancer mortality among retired men who had worked as production or maintenance employees in the asbestos industry and who had been exposed to mixed fibers. Among men with mixed exposure to crocidolite and chrysotile in the asbestos cement industry, the rate was 6.1 times the expected rate. In a British naval dockyard population, Harries (1976) showed that there had been a steep rise in mesotheliomas since 1964. However, the full biologic effects of asbestos in shipyard workers would not have been expected to be detected until the 1970's and thereafter (Selikoff, 1976a).
5
SYNERGISM There is marked enhancement of the risk of lung carcinoma in
those workers exposed to asbestos who also smoke cigarettes (Selikoff et al, 1968; Doll, 1971; Berry et al, 1972; Hammond and Selikoff, 1973); Hammond and Selikoff (1973) interpret the excess lung carcinoma risk from asbestos in nonsmokers to be small. No link between cigarette smoking and mesotheliomas has been observed in a prospective study by Hammond and Selikoff (1973) . A pre liminary study (Lemen, 1976) on female workers employed between January 1940 and December 1967, in a predominately chrysotile asbestos textile plant, revealed 7 lung cancer deaths among 580 women when only 0.63 deaths were expected (p<0.01). One lung cancer death was observed in a smoker, two in women of undetermined smoking history, and four in "never" smokers as determined from hospital admission charts.
It is important to note that the historic documentation of cigarette consumption patterns is lacking for most retrospective cohort studies of asbestos workers. It is further important to note that a sizable portion of the general population, the group usually selected for comparison in these studies, are cigarette smokers. Therefore, the risk of lung cancer demonstrated for these industrial groups exposed to asbestos is of such magnitude as to preclude the identification of an independent etiologic role for cigarette smoking.
A ^C55tTwarc'
T. E. Urbanski, M. Ambler Medical Associates, Inc. 500 Willow Avenue Ambler, Pennsylvania 19002
H. Douglas Neal, M.D. Battery Products Division Chftilotte, North Carolina LOCATION 738
Bautista, M.D. Metals Division Alloy, West Virginia Location 613
E. F. Ritter, M.D. Union Carbide Corporation Films-Packaging Division P.0. Box 198 Centerville, Iowa 52544
G. Oscar Herbas, M.D. Union Carbide Corporation Home and Automotive Products 13160 Crawford Avenue .llsip, Illinois 60658
Frank Edmonson, M.D. Battery Products Division Isheboro, North Carolina LOCATION 737
Philip Falk, M.D. Films-Packaging Division Summit, Illinois LOCATION 358
L. Dale Simmons, M.D. Carbon Products Division Clarksburg, West Virginia LOCATION 721
John H. Ren'tschler, M.D. Metals Division Ashtabula, Ohio
LOCATION 616
M. J. MacKay, M.D. Carbon Products Division Cleveland, Ohio LOCATION 720
J. Anduze, M.D. T 'on Carbide Corporation
Packaging Division P.0. Box 618 Barceloneta, Puerto Rico 00617
R. Richard Dundas, M.D. Battery Products Division Bennington, Vermont LOCATION 739
M. J. MacKay, M.D. Battery Products Division Cleveland, Ohio LOCATION 724
W. C. Bennett, M.D. Carbon Products Division Columbia, Tennessee LOCATION 723
Robert L. Maggs, M.D. 303 West Main Street Freehold, New Jersey 07728
C. D. Miller, M.D. Battery Products Division Fremont, Ohio LOCATION 725
D. H. Tucker, M.D. Union Carbide Corporation Battery Products Division P.0. Box 461 Greenville, NC 27834
Ms. Pat Abercrombie, R.N. Union Carbide Corporation Components Department P.0. Box 5928 Greenville, SC 29606
Miss Ethel J. Stafford, R.N. Union Carbide Corporation Carbon Products Division P.0. Box 849 Greenville, SC 29602
W. R. Mashburn, M.D. Doctors Park 99 Little Pine Hot Springs, Arkansas 71901
Richard J. Sexton, M.D. Chemib^ls and^Plastics Instltufe<^West Virginia LOCATKSN 5T2
C. L. Scott, M.D. Metals Division Bishop, California LOCATION 243
P. Pv%s}(onyha^M.D. ChemicaTs^andPlastics BoundiBfoofcjvNew Jersey LOCATION 312 ^
K. A. Roth, M.D. Chemicaf^agul-'Plas t ic s
~ 'ownaytiTeVTexaa
'^CATMN 526
W. B. Dillard, M.D. Home and Automotive Products Cartersville, Georgia
F. D. Kenney, M.D. Jones CUnlc 110 Ridge Road Munster, Indiana 46321
C. B. Slease, M.D. 183 South Jefferson Street Kittanning, PA 16201
J. E. Turner, M.D. Union Carbide Corporation Linde Division P.O. Box 8 Essington, Pennsylvania 19029
C. E. Taylor, M.D. Union Carbide Corporation Carbon Products Division P.O. Box 500 Lawrenceburg, Tennessee 384
R. L. Skinner, M.D. Linde Division Florence, South Carolina LOCATION 805
E. T. Sheeran, M.D.
v
Carbon Products Division
Fostoria, Ohio
S. A. Harrison, M.D. Union Carbide Corporation Films-Packaging Division P.O. Box 486
Loudoj^||||m^^74 n cr CZ "> v>OOt
V.: R.. S teyar,t, M.D. Metals Division Marietta, Ohio
Chemical^SrutPlastics Mariatfa, Ohio^ LOCATION 314
R. Wempe, M.D. Union Carbide Corporation Battery Products Division P.O. Box 280 Maryville, Missouri 64468
R. F. Rhodes, M.D. Union Carbide Corporation Films-Packaging Division P.O. Box 565 Osceola, Arkansas 72370
R. H. Rucker, M.D. Nuclear Division Paducah, Kentucky LOCATION 174
T. H. Taylor, M.D. 118 North Royal Street 201 Commerce Building Mobile, Alabama 36602
Mobile family Physicians Clinic 2218 FuL&resjk-'Center Mobile, Ariabatoa. 36605
Robert A. George, M.D. Carbon Products Division Parma Research Laboiatory Cleveland, Ohio LOCATION 742
Robert J. Frank, M.D. Battery Products Division Newport News, Virginia LOCATION 736
A. A*Lang, M^P; Union Cubicle Caribe, Inc.
Ponce^'werto~'R4<yjt
LOCATION 293
"<hn Prout, M.D. ,.rbon Products Division Niagara Falls, New York LOCATION 728
A. L. Bax, M.D. Union Carbide Corporation 137 Forth-seventh Street Niagara Falls, New York 14302
Gordon Wolfe, M.D. Union Carbide Corporation Metals Division P.O. Box 03070 Portland, Oregon 97203
J. J. Shehan, M.D. Battery Products Red Oak, Iowa LOCATION 733
T. G. Fortney, Jr., M.D. Union Carbide Corporation Nuclear Division P.O. Box P Oak Ridge, Tennessee 37830
A. S. Garrett, Jr., M.D. Union Carbide Corporation Nuclear Division P.O. Box X Oak Ridge, Tennessee 37830
6. F. Zanolli, M.D. Union Carbide Corporation 'uclear Division ^..0. Box Y Oak Ridge, Tennessee 37830
E. R. Maierhofer, M.D. Home and Automotive Products
J. Huskins, M.D. Union Carbide Corporation Home and Automotive Products P.O. Box 716 Rogers, Arkansas 72756
W. H. Rath, M.D. Union Carbide Corporation Battery Products Division P.O. Box 671 Saint Albans, Vermont 05478
R. L. Yoder, M.D. Union Carbide Corporation Morals Division
Ralph H.'^'Soone-f'M.D. Chemical s^-dnd'-pj^as tics Sisters^ille, Weit Virginia LOCATION 380
R. W. HoTlami, M.D. Chemicals^ml Plastics SouthGtfar lepton, West Virgi LOCATION 514
T. N. Spencer, Jr., M.D. Chemic als^jt{td''P1 as t i c s South Ch^rlepton. West Virgi LOCATION 511 ^
E. Q. Hull, M.D. Chemicals and Plastics South Charleston, West Virgi LOCATION 511
R. H. Spratt, M.D. Union Carbide Corporation Home and Automotive Products 1600 Industrial Boulevard Southampton, PA 18966
Lewis W. Winter, M.D. Union Carbide Corporation Linde Division 4801 West 16th Street Indianapolis, Indiana 46224
D. A. Gard, M.D. Harcourt Clinic, Inc. 1919 N. Capitol Avenue Indianapolis, Indiana 46202
Georfc^Guzzapdo, M.D. Chemicax^nd Plastics Hahnytlle, Lbu4.siana LOCATION 519
H. W. Himes, M.D. Tarrytown Technical Center Tarrytown. New York LOCATION 323
D. H. Glenn, ChemicalspgfKl Plastics Texas^elty, Texas LOCATION 515
Louis A. Trovato, M.D. Linde Division
TnnauanHa. Npu York
L. T. Mcort^M*--? Chemicla><:Sml Plastics Torartnce, California
Location 513
Roy C. (Jumpel, M.D. Rye Medifc^ijjt'bup 269 PurcJjdS^. Street
Rye, Miw York\).0580
I . Keating, M.D. Sterling Forest Research Center Tuxedo, New York LOCATION 242
Lewis LeVin^^M.D. 12 Curds-'lsrreet Meriden* Connecticut 06450
R. D. Haskell, M.D. Union Carbide Corporation Metals Division P.0. Box 94 Uravan, Colorado 81436
I. J. Cohen, M.D. Home and Automotive Products Wayne, New Jersey LOCATION 322
A. D. Gullett, M.D.
j 22nd Floor iII
K. S. Lane, M.D. 22nd Floor
Willis R. Keene, M.D. 1001 North Third Street Folkston, Georgia 31537
W. T. Hausheer, M.D. 22nd Floor
A. Torres-Machin, M.D. lT on Carbide Grafito, Inc. rW. Box 22 Yabucoa, Puerto Rico 00767
Kenneth M. Campione, M.D. Union Carbide Corporation Chicago, Illinois LOCATION 219
J. P. Grade, M.D. Jnion Carbide Canada Limited 123 Eglinton Avenue East Toronto, Canada M4P 1J3
Drs. EllinW^odand Madison Family Pracf*<e^ Center 600 Cent^T'Aventfe Grand Junction, Colorado 81501
L. M. Ru^in, Mt. PleasahJ<d<edical Group AnQ Columbus Avenue
v> halfa. New Ydk 10595
Homer T. -Yod^r7 M.D. 20997 Lopdn^Rtjad Fairvidw Park, Oltio 44126
.,
ft '