Document JzpNZrJpG08Em4DgmLnOaMmr

In our final draft, the permit requirement of Part II ha5 been restricted to manufacturing emission sources. This is in accord with the Agency testimony that presently it has inadequate staff to handle the permit load created by a blanket requirement. manufacturers of asbestos products must obtain a permit by June 30, 1972. All " Part III prohibits the spraying of asbestos-containing insula tion and fireproofing. Experience has indicated that procedural safeguards are inadequate and their enforcement is an overtaxing burden. Procedural safeguards designed to reduce fiber emissions would be required to spray non-asbestos insulation. The biological effects of these fibers is unknown. Prudence would seem to dictate .reasonable efforts to soften the potential future, blow from, spray fiber aspiring to asbestos' status. " .. * Part III requires that various asbestos-related activities at construction sites be done within an enclosure. It would also require that asbestos construction products be so installed as to preclude the emission of fiber into the circulating air. In the interest of efficient enforcement the numerous restric tions on the spraying of non-asbestos fibrous material have been reduced to requirements for enclosure and for vacuuming. Also this section has been changed to make clear that these safeguards are required only when spraying of non-asbestos materials occurs in an area open to the atmosphere. This "open to the atmosphere" modifica tion has also been added to the section controlling the cutting, trimming, fitting or stripping of asbestos-containing materials at a construction site. Part III now contains a "no visible emission" standard which must be met regardless of adherence to the required procedural safeguards. This should permit easier enforcement and tend to insure greater compliance with the safeguards. The original proposal contained two regulations controlling the general application of asbestos-containing materials and the application of non-asbestos materials in air ducts or plenums. This has been altered to require that only asbestos-containing mater ials, used in any construction work, be so installed as to preclude emission of the fiber to the circulating air. There is little medical data available to prove or disprove the toxic effects of the multitude of non-fibrous construction material, although one such product, fiberglass, would appear to be biologically inert. The Board prefers to act on the safe side of health in regard to spray ing operations, which can emit large quantities of fiber if uncon trolled. In any event, such uncontrolled emissions constitute a nuisance dust and could be controlled on that basis alone. These reasons do not apply with equal force to the non-spray application of non-asbestos materials in construction. 3-457