Document K6QxY0V7DR9aRdqvEpyzvzKYX

r GllCjr'ltlASBESTOS UNION CARBIDE CORPORATION METALS DIVISION P. 0. BOX 579 . NIAGARA FALLS, N.Y. 14302 TEL: 718-278-3376 November 21, 1978 (see attached distribution list) Dear Enclosed are copies of the following items presented to the Standards Board in connection with the spraying of asbestos-containing materials: 1. Dr. Rhodes' oral testimony. 2. Additional testimony on H. B. Fuller test presented at the Hearing. 3. Additional testimony submitted under a 15-day extension of the Hearing. These items are in addition to the written testimony sent to you last month. The Hearing seemed to go well for the products containing wetted and encapsu lated fibers. Dr. Rhodes and Mr. Beemer are to be congratulated for their excellent oral presentations and handling of questions. I plan to meet with Dr. Ottoboni the week of December 4 to determine the potential action of the Board, who were reminded during the Hearing that a decision by early in 1979 would be appreciated. We will keep you informed of any activities concerning the issue, but don't hesitate to call if you have any questions. Harry will be out of town until the first of December. Very truly yours. Marketing Manager JLMrdal Enclosures CC: Dr. H. B. Rhodes UCC 013866 Mr. Paul Beemer W. W. Henry Company 5131 Becket Street Huntington Park, CA 90058 Mrs. Stella Miller National Paint A Coatings Assoc. 1500 Rhode Island Ave. NW Washington, DC 20005 Mr. Herb Duckett, Executive Secretary Roofing Contractors Assoc, of So. Calif., Inc. 11401 East Valley Blvd. El Monte, CA 91731 213-579-1276 Mr. B. J. Pigg Asbestos Information Assoc./NA 1745 Jefferson Davis Hwy. Crystal Square 4, Suite 509 Arlington, VA 22202 Mr. John T. Banister, Executive Director Associated Roofing Contractors of the Bay Area Counties, Inc. 8301 Edgewater Drive Oakland, CA 94621 Mr. Jim Hay The Flintkote Company 5500 S. Alameda Street Los Angeles, CA 90051 Mr. M. M. Golden Standard Brands Paint Co., Inc. 4300 W. 190th Street Torrance, CA 90509 Mr. R. C. Nunn Chevron Research Company 576 Standard Avenue Richmond, CA 94802 415-237-4411 ext. 4139 Mr. Dimitry Poutiatine Johns-Manvilie Corporation Ken-Caryl Ranch Denver, CO 80217 Ms. Margo Parker General Motors Corporation Room 11-141 GM Building 3044 W. 6rand Blvd. Detroit, MI 48202 Mr. George Fay Carboline Company 350 Hanley Industrial Ct. St. Louis, MO 63144 Mr. Gordon Coates, President Calaveras Asbestos Limited P. 0. Box 127 Copperopolis, CA 95228 209-785-2201 Mr. Richard Carter Johns-Manville Corporation Ken-Caryl Ranch Oenver, CO 80217 Mr. Bruce Radebough Mortell Company 401 Industrial Drive Plymouth, MI 48170 UCC 013867 e (/ xaSESTOS UNION CARBIDE CORPORATION METALS DIVISION P. 0. BOX 579 . NIAGARA FALLS, N.Y. 14302 . TEL: 716-278-3376 November 21, 1978 (See Attached Distribution List). Dear Enclosed are copies of additional testimony submitted to the California Health and Standards Board in connection with the Hearing on SB-1591. Please let us know if you have any questions on the enclosed or on the testimony originally sent to you on October 23, 1978. Very truly yours. lyers ing Manager JLM:dal Enclosures CC: Dr. H. B. Rhodes 1. Asbestos Fiber Exposure During the Destruction of Maintenance Coatings by Sandblasting, 2. Airborne Asbestos Concentrations from the Grinding of Themoset Resins Containing 0.8-18% by Weight Chrysotile Asbestos 3. H. B. Fuller Company Presentation 40836g UCC 013868 I Mr. George Borg Riverside Cement Company 1500 Rubidoux Blvd. Riverside, CA 92509 Mr. James Heacock California Dept, of Health 1449 West Temple Street No. 231 Los Angeles, CA 90026 Mr. James Hecht Senator Marks' Office Room 2070 State Capitol Sacramento, CA 95814 Mr. James Mason California Dept, of Health 1449 West Temple Street No. 231 Los Angeles, CA 90026 Mr. Robert Locke W. R. Grace & Company 62 Whittemore Avenue Cambridge, MA 02140 Mr. Kurt Schwartz Senior Vice President Supradur Manufacturing Corp 122 East 42nd Street New York, NY 10017 Mr. Forrest D. Simmerman Technical Director Texas Refinery Corporation One Refinery Place Fort Worth, TX 76101 Mr. David Townsend Senator Presley's Office Room 4076 State Capitol Sacramento, CA 95814 UCC 013869 ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD, NOVEMBER 8, 1978 Mr. Chairman, Members of the Standards Board. My name Is Harrison Rhodes and I am employed by Union Carbide Corporation. The continued use of certain products wherein the asbestos fibers are wetted and encapsulated is extremely important to a large number of California manufacturers and users. They are represented here today by a number of experts who are prepared to answer any technical or business questionsyou may have. You have already received our written testimony and there is little point in reiterating it here today, although we can discuss it more thoroughly at your discretion. My intent is to show you some samples of the products so you can see what we are talking about. These samples show both the products in the form to be sprayed and the final product after cure. I will also summarize a spraying study which appears to be quite relevant and which came to my attention after the written testimony was prepared. A complete copy of this report was submitted to Mr. Rinaldi yesterday and may be in your folders. Let me emphasize that we are discussing only products where the asbestos fibers are wetted and encapsulated from manufacture through final usage. These include the coating and laminating materials and both types of fibrated roof coatings, that is those manufactured from cold-process cut back asphalt and those from emulsified asphalt. Me are not addressing the Portland cement plaster or the naturally occurring impurity portions of the hearing. A0839C UCC 013870 -2- As a frame of reference, let us first look at the asbestos-containing spray insulation material of the type that was the principal target of the 1974 legislation (60% mineral wool, 25% asbestos, 15% Portland cement.) This is the material as it was delivered to the construction site and this is what it looks like after application. Notice that I can pull it off with my fingers and crumble it to a powder. To use the Federal EPA definition it is friable. Excessive dust generation would be expected during field mixing and during renovation or removal. There are no objections to the banning of these materials and any like them. In contrast to this extremely friable material, all of the products for which we are requesting exemption must perform a protective or structural function which is defeated if they become friable. The first examples are a polyester laminating resin containing about three-quarters of one percent asbestos and a maintenance coating with about 2.5%. The laminating resin is used in conjunction with fiberglass to build up strong, rot-resistant structures such as boats. This is an example of one layer of the cured product. It is normally built up in layers to a thickness of a quarter of an inch or more. This is the finished maintenance coating containing 2.5% by weight asbestos. It is also hard and definitely not friable. Next are two examples of roof coatings. This one has an emulsified asphalt base and this one uses cutback. They contain about 9 and 7 weight percent asbestos after cure, respectively. Note that the cured coating is slightly flexible or resilient. These products must be formulated this way to allow for the effects of temperature change. A set of roofing product samples containing a much wider range of asbestos contents has been prepared by the W. W. Henry Company and will be described subsequently by Mr. Paul Beemer, A 08 3 9 1 the General Manager of that company. UCC 013871 -3- The spraying test I mentioned earlier, which was not included in our written testimony,'was conducted by a consulting firm for the H. B. Fuller Company. This study was submitted by H. 8. Fuller as part of their testimony on a proposed Federal EPA regulation on the spraying of asbestos-containing materials. The materials sprayed consisted of a series of mastics used to provide weather-barrier coatings over soft thermal insulation on tanks, roofs, lines, etc. Asbestos contents were 1.8, 6.6, and 14.3% by weight chrysotile and a mixture of 13.7% chrysotile and 34.9% of Asbestine Fiber #2 talc. It is important to note that although Asbestine Fiber $2 is talc, not asbestos, it does contain a substantial portion of mineral particulate which would have been counted as asbestos by the consultant making this study if it became airborne. The mastics were sprayed under two sets of conditions; in a closed 20x20 foot room to approximate the worst possible case, although the products are not normally used indoors; and in an outdoor application. The airborne fiber counts found are presented in this figure in the same manner as the other data in Figure 1, page 10, in the testimony. The fiber concentration in fiber/cc longer than 5 microns is shown on the vertical axis. The present DOSHA allowable limits of 10 fiber/cc ceiling, 2 fibers/cc TWA and the 1 fiber/cc maximum TWA set by SB-1591 are shown for reference. The four mastics are arranged in order of increasing mineral content from 1.8 to 48.6% by weight after cure. The solid circles show the operator breathing zone concentration. These are all in the 0.1 -0.2 fiber/cc range. The bars show the maximum or ceiling values, the range, and the arithmetic mean for the area samples in the immediate vicinity of the spraying operation. The highest value found was about 0.5 fiber/cc for the non-typical interior spraying of the Hi Mastic. A 083 The remaining values were in the zero to 0.2 fiber/cc range. As an aadedr UCC 013872 -4point of interest, the Gallo Company sprayed 40,000 gallons of the Monolar Mastic containing 6.6% asbestos to insulate the exterior surfaces of wine storage tanks located out-of-doors in Modesto. Air samples were collected on membrane filters. No airborne fibers were detected by microscopic examination. The important point to note in these data is that the airborne fiber concentrations are all very low with no clearly defined trends with mineral content in the material being sprayed up to a total mineral loading of 48.6% by weight after cure. This result is very similar to the spraying and product removal data given in Figure 1, page 10 of the written testimony, indicating quite conclusively that the aifborne asbestos exposure does not change a measureable amount with the asbestos content as long as the fibers are thoroughly wetted and encapsulated. For these products to be commercially useful, they must be wetted and encapsulated. To conclude, the products with which we are concerned perform a useful and valid service for industry and for the general public. They contain wetted and encapsulated fibers which do not expose workers to fiber levels in excess of those established by DOSHA or SB-1591. We would not be here today if we were not convinced that the products could be used safely and within the confines of existing regulations. We request that continued use of these products be permitted by your action to modify Section 5208* Title 8, as: suggested in our written testimony including a maximum allowable TWA exposure of one fiber/cc >5y. Thank you very much for the opportunity to express these views. With your permission, Mr. Paul Beemer would like to present the additional samples mentioned earlier. UCC 013873 4 08 SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH ANO SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Cal/OSHA and Union Carbide Sandblasting Comparison Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento, California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York A08334 UCC 013874 BACKGROUND During the hearings on the 1976 Presley Bill, Assemblyman Fenton asked the Department of Health to collect additional exposure data during the use of the products for which temporary exemptions were granted. A cooperative government-industry effort ensued. The first portion of the data is contained in a letter of June 1, 1977 from Jerome A. Lackner, M.D. to Mr. Fenton. A copy of this letter is attached. These data have been submitted to the Standards Board as part of the record for this hearing. The initial two tests (see Location 1 and Location 2 in the Lackner letter) involved sandblasting of an asbestos-containing coating from a plaster or a stucco wall. When the results became available, they were higher than anticipated, i.e. 0.5-3 fibers per cc longer than 5u. The manu facturer of the paints asked Union Carbide to participate in a third test jointly with the DOH. This was quite acceptable to the DOH and a series of paired samples was collected at Location 3. A detailed Union Carbide report on this test is attached. DISCUSSION The samples collected in the third test were extremely difficult to count. They were heavily loaded with both fibrous and non-fibrous dust. A lot of particulate was present that met the dimensional criteria of a fiber, length greater than 5y, length to diameter ratio greater than three but was almost certainly not asbestos. Both counters were experienced and discussed the problem of evaluating filters of this type prior to counting. The results from the two laboratories are summarized and compared in the following table. The Cal/OSHA data ranged from 0.1 to 7.1 fibers/cc >5p and the UCC values from 0.0 to 3.3 fibers/cc >5y. A0839b UCC 013875 2 COMPARISON OF AIRBORNE ASBESTOS FIBER COUNTS DURING SANDBLASTING OF ASBESTOS-CONTAINING MAINTENANCE COATING Description of Operation Pretest Control* On fence, left side of area to be sand-blasted. *4 1/2' above ground. On fence,^100' from G-16. --5* Above ground. Personal sample on observer *2$* from fence and moving parallel to fence. Samole Oata lime Total Ho. On Off Hin. 6-16 10:35 10:56 21 F-44 10:42 10:59 17 A-86 10:39 10:52 13 Observer (Ouring Sand-Blastinq) Personal sample on observer A-81 11:12 11:18 **20-30* from fence and moving 11:25 11:27 parallel to fence. Saaw as A-81. J-89 12:26 12:52 Area sample on fence. 5` 5-3 above ground and -40' down wind. (In lieu of observer) 1:35 2:00 6 2 8 26 25 Helper (During Sand-Biastina) Personal sample. Assisting with hoses. Operating sand feeding equipment. G-48 11:10 11:18 8 11:24 11:26 2 Iff Saaw as 5-48. X-8 12:25 12:48 23 Same as G-48. Same as 6-48. C-iS X-4 1:08 1:36 1:22 14 1:58 22 Blasting Operator (Ouring Sand-Biastina) Personal sample. Operator handling sand-blasting noille, standing-2' from fence. 0-71 11:10 11:18 8 11:24 11:26 2 Same as 0-71. X-14 12:25 12:36 11 Same as D-71. 5-34 12:38 12:46 6 Same as 0-71 except Inside of hood. Same as 0-71. x-z 1:08 1:22 14 X-3 1:36 1:58 22 CcT" 100 fields Ucc Cal/OSHA f/cc Fiber Counts Asbestos UCC SCM (f/cc) Non-Asbestos Total Cdnitients 2 0.1 0.3 00 0.1 2 0.1 0.2 l 0.1 0.1 1 0.03 0.2 3 Asbest 29 0.7 1.9 0.2 0.9 1.1 fibers i 25 field 15 1.0 1.4 28) 45) 1.1 2.2 3 0.2 0.5 2 0.06 0.2 32 2.2 1.6 0.2 3.9 4.1 1 asbest' fiber in 25 field: 3) 58) 3.2 7.1 38 1.3 (.6 34 1.7 2.1 0.0 1.1 1.1 0 asbest: fiber in 50 field- UCC 013876 A83se -3- PISCUSSION (Continued) For the pretest controls and several of the samples collected on the observer and on the helper, only several fibers were found in the hundred fields examined under the microscope. Blank filters, i.e. those which have never been exposed, will read from 0 to 3-4 fibers per 100 fields, so these results are not significant. The remaining seven pairs ranged from about the same to Cal/OSHA counting about double. Considering that these counts are not from the same filter but from filters that were collected on opposite shoulders, both laboratories felt that the agreement was really excellent. The corresponding time-weighted averages for the two operators for the time period where sandblasting was actively in progress and for the entire eight-hour day are listed below. The two workers' actual TWA exposures for the particular day were all below 0.5 fibers/cc >5p. Time-Weighted Average Exposures (Fibers/cc>5p) During Active 8-Hour Day Operations Basis Cal/OSHA UCC Cal/OSHA UCC Helper 1.1 0.6 0.2 0.1 Operator 4.1 2.2 0.4 0.2 It appeared from the results that non-asbestos material was being included as asbestos in the counts reported. In order to check this further. Union Carbide examined three of the filters with a scanning electron microscope at 1000X. A total of only four chrysotile fibers was found in a hundred fields. 40S3S7 UCC 013877 -4- Wben these results became available, the problem was discussed with Mr. Heacock at the DOH and it was agreed that another carefully planned large-scale test should be made. A copy of a letter to Mr. Heacock outlining the objectives and protocol for such a test is attached. The report of this test was appended to our written testimony and the results were described therein. CONCLUSIONS We believe that the fiber counts reported in Or. Lackner's letter of June 1, 1977 include a great deal of material that is not asbestos. The subsequent large-scale test is more representative of potential exposure during sandblasting. UCC 013878 A83S8 r<!5) se.t-Jroo, Ext. joj 7. r 4 -,vi * k `J.;. *. - 7, .* *>.*-*, *I.:'-.:. .-' ,'r. - ; r'; -.. r YY . ' Y VY;^:YY' -Y'"-~Y '.'YYY"-' . .'/' */*:.June i. i>:77 *' : * Y *' A~-*>/* * ^ * . ** - * . * ' !* * . ' '*..** . ' - * /< .7 .... ?,- . >-<, . r',: : .' Eenorablo Jacfe R. Fenton, Chalrr-*.i ; Subcos^-Hstitrtc/`oct on Occupatioionnaail CS-affeVtfyy ; ;V-i:Y.Y ' ` sad Health Scsto Aasc:cMy ;: Stc.ro Capitol Snercnanto, CA S'*I< . * I' .' Dear Hr. Fo.iton: . This report is la resrrrr.se to the request by Berbers of ths Axscshly-fubcocsittec a Ir.iusrrlal Safety for Ecasurereuts of vorkcr ensures to asbestos durinj . coristruction opera-ions* . Although industry representatives resairod la close contact vlth staff of the iOccupational Health f-rr.nch throurr.CHrt the ysar, no ercort'n-.Uy arose to vltr.ess -and evaluate an actual destruction of a prcrioisly-sppliod, esbastos-containins ^product, either es < paint or J stucco co=pocut. .. The encloseJ rryort it of verier exposures durl.rx sta.-ed sas-lin; ani sandblasting removal of previously applied protective coctlnrs contc-ining asbestos. Tio re- \ Rovnl. vas conducted by industry representatives at the direceion of Deportment of . Jjcaltb ectrloyccs. InJustly representetires tuvo si".co statc-i the reneval does not represent ccteal pructico: i:e.iith f-epirtcent representatives believe it does. As a result of this experience, wh.cn suppliers ef portlaud csPent piaster cor.tain- .Irc csbostos ceuM xct identify s suitibl* bail din 7 about to be d7li3hed, nnd . offered to construct mi then stage t'-.o Ccrolitioo of a stmcttire^ their offer *. was acioovied^ed but not.pursued. , '; >- X fcl that vith tha receot ennctncr.t of stringent reportin'; ro^iresents cn the ose of asbestos in all places of etsploynent in CalifornJa, proper controls vill . be dcvoloped ar;4 used for ell occupational exposuTos. ;;v--t - !* ' *v ' If vo ccs bo of further aasistacce to the Cosnlct** plcaso do not hesitate to r-contact to. ;.V?r'.Vy/' -*:v -. ' *. i-.-r; ;V-.* Sincerely, ' Orlglca^ Sley-e^ By *V w* Jeroce A- L^nckner, Director of Health ; Jroee A. LacXr.er, 1L.D. Director of liiiltb 'V=F*?'*.v\ *r-j , ;*' * "/'j*, *.' v- , * H, .fnclosure ?s - -..I: bca Henlth ar.i tfelfaTe Agency Lorislativc Liaison . JHH.-dka . - .. .. Public Iloslth Division Cccupatlocal J'cilth Pranch ' fred 1. Ottoboni, Ph.D. UCC 013879 Report of Errploycc Exposure to Asbestos During Destruction of Spray Coatings Previously Applied to Buildings or Structures INTRODUCTION During 1976 the Occupational Health Branch of the Public Health Division of the California Department of Health agreed to conduct a series of self-initiated studies of worker exposures to asbestos during destruction of spray coatings. Exposures from two products were to be evaluated; portland cement plaster contain ing less than one half of 1 percent asbestos and exterior and interior coatings and laminating resins containing encapsulated asbestos fibers previously applied to a building or structure. Studies were made at three different locations to evaluate employee response to asbestos as follows: 1. On August 31, 1976, a study was conducted at 4801 Exposition Boulevard, Los Angeles. A latex-based paint containing 1 percent Chrisotile asbestos, which had been applied to a plaster wall in an unventilated hallway five feet wide and eight feet long, was sanded for two hours with an electric hand sander. The operator was aware of the purpose of the study and at tempted to remove the paint without cutting into the plaster. 2. On November 16, 1976, a study was conducted at 950 South Broadway, Los Angeles. An alkyd-based paint containing about 4 percent' Chrysotile asbestos had been applied to a stucco wall. The test was conducted at the rear of the building in an alley, a 20-foot section of the wall was sandblasted to a height of five feet using a commercial sandblasting machine. 3. On December 17, 1976, a study was conducted at Village Grove Park in the city of Corona. An epoxy-based paint containing 1 percent Chrysotile asbestos had been applied to a metal fence. The test was conducted by sandblasting the fence using a commercial sandblasting machine. Samples were taken upwind, downwind, inside and outside the sandblasting hood, at the hosetenders location and in the general area. All of the airborne samples were evaluated using our Cal/OSHA method which is iden tical to the OSHA- and NIOSH-approved method specified in the asbestos standard. Material samples were also evaluated to determine the percentage of asbestos in the paint. The summary of the airborne concentration of asbestos during the sampling period is attached. The data shows that there is a definite exposure to asbestos when employees or workers sandblast or sand coatings containing asbestos and that this exposure is present in the immediate area. In this case, the immediate area referred to is within a 10-foot radius of the source in the non-windy condition and within a 40-foot radius downwind in windy conditions. UCC 013880 2- - In any case, at all three locations there was an employee exposure of at least 1 fiber/cc, and up to 4 fibers/cc as an average. The area samples also showed exposure into the 1 to 2 fiber/cc range. And finally the mixer-hosetender exposure range was from 0.5 to 2.0 fibers/cc. DISCUSSION All of the samples collected were of short-term exposures of 10-to-20 minute duration. All showed that free asbestos fibers were released. Dry sanding and sandblasting using dry silica sand may not represent industry-wide practice, but have been witnessed by Health Department representatives at other sites, and with other coatings, frequently. No studies were made of destruction of portland cement plaster coatings contain ing asbestos as no buildings were located containing such a coating that were to be demolished. STANDARD The Cal/OSHA standard is: "The 8-hour time-weighted average concentration of airborne asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers, per cubic centimeter of air as determined by the membrane filter method using phase contrast illumination and 400 to 450X magnification. The ceiling or short time concentration to which employees are exposed shall not exceed 10 fibers, longer than 5 micrometers, per cubic centimeter of air." May 1977 UCC 013881 Suncaary of Airborne Concentrations of Asbestos LOCATION 1 Material - Latex Base Paint (Vinyl-Acrylic) - 1% Chry30tile asbestos bound in matrix. Free fibers released with grinding abrasion. Sander f/cc* Area Samples f/cc* 1.7 0.3 Both samples simultaneously within 10 ft. of source 1.1 0.9 " 0.5 0.3 " LOCATION 2 Material - Alkyd Base - 3-5Z Chrysotile asbestos. Free fibers released with sandblasting. Sandblaster f/cc*Mixer-Hosetender f/cc* Area Samples f/cc* 1.5 (filter outside 0.4 of hood) 3.5 _____________________ 0^7 3.5 1.6 All 3 sampled simultaneously 1.2 LOCATION 3 Material - Epoxy Base - 1Z Chrysotile asbestos. Free fibers released with sandblasting. Sandblaster f/cc* Mixer-Hosetender f/cc* Area Samples f/cc* 0.3 (Stationary Background) Upwind Before 0.2 (Moving Background) Blasting ____________ 0.1 (Stationary Background) tfovinc 1.6 (Filter outside of hood) 7.1 n 6.6 n 3.7 (Filter inside of hood) 2.1 (Filter outside of hood) 1.4 0.1 (Moving during blasting) Never downwind - 2.2(Unwind) 0.2 0.5 If 0.2 tl 1.9 (Stationary during blasting) Downwind *f/cc . fibers per cubic centimeter of air greater than 5 microns in length NOTE: Horizontal lines denote samples collected in the same time ^rane <5> ^ Op \ UCC0J3882 AIRBORNE ASBESTOS COUNTS for Textured Coatings of America, Inc. (Village Grove Trailer Park, Lots 19 and 20) Corona, California Date Sampled: December 17, 1976 Date Reported: April 1, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: B. L. Ingalls & G. J. Spencer Union Carbide Corporation Reported By: H. B. Rhodes Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013883 OBJECTIVE To measure the airborne asbestos fiber concentrations generated during the removal of an asbestos-containing maintenance coating from a sheet metal fence by sand-blasting. DESCRIPTION OF OPERATION The test was run at Village Grove Trailer Park, Lots 19 and 20 in Corona, California. The park was surrounded by a galvanized metal fence about 5' high that had been painted about five years previously. The metal was first primed and then painted with an alkyd-based maintenance coating containing about 5% asbestos. The paint also contained mica, talc (non-tremolitic), fiberglass, and perlite. The sandblasting was done with a portable unit consisting of a compressor and a blasting unit. The latter had a sand storage tank about 1' in diameter by 3 1/2' long which fed silica sand through a lever operated control device and a heavy hose to a blast nozzle, under the control of the operator. One man handled the blasting nozzle while the other operated the compressor, assisted with the hoses, but primarily operated a lever on the sand delivery unit to keep the sand flowing. The nozzle operator wore a conventional sand-blasting hood with air openings on the sides. During the blasting operation one man stood about 2' from the fence and moved the nozzle, held about 3-6 inches from the fence, in short arcs until the impinging sand removed the paint down to the base metal. Bonding was excellent and it took at least several passes of the blast to remove the paint. The material removed was finely pulverized. The bottom 1 1/2' of the fence was not hand-blasted to avoid raising extraneous dust from the dry ground at the base of the fence. The weather was clear and warm with a light, variable breeze blowing from left to right in approximately the same direction as the fence. SAMPLE COLLECTION The following types of samples were collected during the test: 1. Background samples prior to testing were collected at the fence, ~4 1/2' from the ground about 100' apart. (Spanned the section to be sand-blasted.) (G-16 & F-44) 2. A sample about 40' downwind, on the fence about 5' above the ground, during the last 25 minutes of sand-blasting.(G-3) 3. Personal samples on an observer in an area generally 25-35' from the blasting operation and approximately perpendicular to the blasting. (A-86, A-81, J-89) 4. Personal samples on both the helper and the sand-blasttya operator. All operator samples were external to the hooft^ except X-2. Helper - G-48, X-8, C-15, X-4 Operator - D-71 , X-14, G-34, X-2, X-3 UCC 013884 COUNTING EQUIPMENT AND PROCEDURES All samples were collected with battery-powered air pumps (M.S.A.), calibrated to 2 liters per minute on Millipore membrane filters of 0.8g porosity. The samples were mounted and counted in accordance with the procedure of Bayer, Zumwalde, and Brown (Bureau of Occupational Safety and Health, February 1969). Counting was done with a Nikon microscope at 400X utilizing a Poton reticle with a 0.0062 mm2 field area. One hundred fields were counted for all samples. These samples proved to be particularly difficult to count. Out of the total of nine personal samples from the blast operator and the helper, six were loaded with dust to a level where filter areas were frequently obscured. When such an area occurred, the counter went on to another field. There is no way to tell how this may have influenced the results. Our normal practice in this situation is to resample, but considering the difficulties this would entail, the filters were used. In addition to this problem, the nature of the samples puts an extreme strain on the method. Thus: 1. Fiber concentrations were low with 0.58 fibers/field the maximum and 0.2 fibers/field more or less typical. This is well below the 1-5 fibers/field range recommended by NIOSH. 2. The fibers counted were in the 5-15y range so that the "5m decision" was a frequent requirement. 3. There were substantial concentrations of mica "chips" present. These can generally be recognized as not asbestos but certain shapes around 5y in length can become undistinguishable. These factors of low fiber concentration on the filter, filter size distribution, and potentially interfering "fibers" result in a high degree of operator discretion in the determination of the total number of asbestos fibers counted. When this possible variation is combined with the short sample times substantial variations can result. In view of these uncertainties, a modification was made in the procedure to report two categories of fiber: 1. Obvious chrysotile asbestos. Either long and curved, or distinctly thin and slightly curved in the 10-20u range. 2. Probable asbestos fiber: Particles which did not have obvious identifying asbestos features but met the l/D >3, >5y require ments and were dark and fiberlike under phase-contrast illumination. When there was any doubt about a fiber's identity it was included in category 1. Particles which were obviously not asbestos were not included. The total of 1 and 2 would be the value ordinarily reported as asbestos. UCC 013885 A RESULTS AND DISCUSSION A description of each sample and the respective fiber concentrations are shown in Table I. The data obtained by Counter A are presented graphically in Figure I. Where paired results are available Counter B was high six times and Counter A three times. The differences, without regard to sign ranged from 0.1 to 1.1 fibers/cc and averaged 0.3 fibers/cc. In view of the counting difficulties on these slides we consider this to be good agreement for operators in the same laboratory counting the same slides. The operation of the sand-blasting equipment was too erratic to provide a. meaningful estimate of operator TWA exposure'for normal day's oper ation. Using just the time periods during the actual blasting operations, the time-weighted averages would be: Operator - (10)(2.2H(n)(3.2)+(8)(3.28)+(14)(1.68)-t-(22)(1.76) (10)+(11)+(8)+(14)+(22) 145.68 65 2.2 fibers/cc >5v Helper - (10)(1.03)+(23)(l 1)+(14)(Q.15)+(22)(Q.Q$) (10)+(23)+(14j+(22) _ " 39.02 69 = 0.6 fibers/cc >5y The measured exposure for the full 8-hour day would be: Operator - = 0-3 fibers/cc >5y Helper - 39^02 = Q QQ f^ers/cc >5y UCC 013886 4 TABLE 1 SUWWRY OF AIRBORHE ASBESTOS FIBER COUNTS DURING SANb-blASTING OF ASOTTfM^COfITAt WTHG~HA 1 nTPwi'CE COATING Description of Operition Pretest Controls On fence, left side of ire* to tie sand-blasted. 41/2* above ground. On fence, ~,10Q' from 6-16. -->5' bove ground. Personal siigile on observer "25' from fence and roving parallel to fence. Sample Data Time Total No. On Off Min. fi-16 10:35 10:56 21 F-44 10:42 10:59 17 A-86 10:39 10:52 13 Airborne Fiber Concentrations (Fibers/cc >5u) 6bvious Chrysotile fibers tOO Melds f/cc Operator "A* Probable Asbestos fibers 100 fields f/cc Total Asbestos fibers 100 Melds f/cc Operator **B" Total Asbestos fibers TOO fields f/cc 00 2 0.07 2 0.07 * 00 00 00 00 2 0.08 2 0.11 2 0.11 4 0.21 Comments Observer {During Sand-Blasting) Personal sample on observer A-ei 11.-12 --20-30* fro* fence and moving 11:25 parallel to fence. Same is A-81. J-89 12:26 12:52 Area sanple on fence. S' G-3 above ground and -'40' down wind. (In lieu of observer) 1:35 2:00 co r-. 6 2 8 26 25 00 1 00 1 7 0.19 22 0.09 1 0.03 0.61 1 29 0.09 - 0.03 0.7 21 * 0.6 Helper (During Sand-Blasting) Personal sample. Assisting with hoses. Operating sand feeding equipment. 6-40 11:10 11:18 8 11:24 11:26 2 Iff Same as 6-43. X-8 12:25 12:48 23 Sam as 6-43. Sant is 6-43. C- IS X-4 1:08 1:36 1:22 14 1:58 22 1 0.07 14 10 0.30 18 1 0.05 00 2 2 0.97 15 0.54 0.10 0.06 28 45 3 2 1.03 9 0.84 1.35 0.15 0.06 60 9 0.6 1.8 Heavily loaded; hard to count second slida 0.3 Blasting Operator (Ouring Sand-Blasting) Personal sample* Operator handling sand-blasting nozzle, standing-"?' from fence. D-71 11:10 11:18 8 11:24 11:26 Z Sane as 0-71. X--14 12:25 12:36 M Satie as 0-71. 6-34 12:38 12:46 8 Same as 0-71 except inside of hood. Same as D-71. X-2 1:08 1:22 T4 X-3 1:36 1:58 22 7 0.48 25 1.72 32 2.21 13 0.82 30 5 0.43 33 8 0.39 26 21 0.66 35 i.8a 2.84 1.28 1.10 43 58 38 34 56 2.70 3.64 3.28 1.68 1.76 75 39 53 Heavily loaded, hard to count. 4.70 3.36 - Heavily loaded; hard to count second slide Heavily loaded; hard to count. * 1.66 * UCC 013887 -408407 < UCC 013888 Of A5BESTOS-CONTAIN1HS W1HTEHAIICE COATING UNION CARBIDE CORPORATION METALS OIVISION P.O.BOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 716-278-3376 January 13, 1978 Mr. James Heacock Occupational Health Section California Department of Health 2151 Berkeley Way Berkeley, CA 94704 Dear Mr. Heacock: The suggested protocol for the cooperative test that we discussed in your office is attached. As you requested, it has been set up so that the Department does the actual sample collection. Plans are well along to conduct the test on one or more large tanks in the Trona area that have been coated with zinc-rich primer. The only hold up is satisfactory verification of composition of the primer. We would like to go ahead and plan to conduct this test during the week of January 23, 1978, preferably on Tuesday the 24th. Please let me know if this is satisfactory so we can finalize on a date and the other arrangements. In view of the time that has passed since the original hearings and the number of new people involved, it seems appropriate to comment on two questions relevant to the previous testing results reported in a letter of June 1, 1977 from Jerome A. Lockner, M.D. to the Honorable Jack R. Fenton, i.e.: 1. The appropriateness of sandblasting as a representative test method. 2. The accuracy of the previous counts. We have been informed by a large manufacturer of the high-performance mainten ance coatings of particular interest here that certain of these coatings are sandblasted as a routine procedure. Usually it is a light "brush" blasting to remove rust spots and loose coating but occasionally complete removal takes place. Sandblasting thus represents an extreme condition and should thus be a reasonable way to approximate the upper limits of exposure. UCC 013889 A Mr. James Heacock -2- January 13, 1978 As we discussed several times, in the test where Cal/OSHA and Union Carbide collected side-by-side samples during a sandblasting operation, both laboratories found asbestos counts of several fibers/cc or more when counting by the routine NIOSH procedure. It is well recognized that the procedure has very serious limitations for dusts of the type generated during sandblasting. Subsequent examination by Union Carbide of several of the filters using scanning electron microscope techniques suggested that both laboratories may have counted substantial numbers of non-asbestos particles as asbestos and that free asbestos fibers were extremely rare. Over the past year the Federal OSHA Laboratory at Salt Lake City has adopted more sophisticated optical techniques to distinguish asbestos from other particulate matter and are quite possibly the most skilled laboratory in the country in this area. I have discussed our problem with the Director, Mr. Floyd Madsen, and he is agreeable to count a reasonable number of samples. It will be appropriate for you to make a written request for this assistance at the time the samples are submitted. Please let me know if you have any problems with this proposal. We are looking forward to participating in what appears to be the first carefully defined test of asbestos exposure in this type of application. It was a pleasure meeting with you and the others in Berkeley. Very truly yours Harrison B. Rhodes Technology Manager HBR/rmm Attachment UCC 013890 lc TEST PROTOCOL OBJECTIVE The objective of this test is to measure the airborne concentration of asbestos fibers generated during the removal of a non-resilient maintenance coating by sandblasting. The site selection, test operation, sample collection, and sample analysis will be carefully planned in advance so that meaningful results are obtained. WORKING ARRANGEMENTS The selection of the test site and provision for the sandblasting operator and equipment are the responsibility of the Union Carbide Corporation with the choices subject to approval by the Department of Health. It is intended that the Department of Health and Union Carbide will each have at least one qualified person at the site to work out a mutually acceptable sample collection strategy in accordance with the general guidelines under "Sample Collection Strategy". Sample collection will be performed by the Department of Health. After collection is completed, a validated summary sheet of the collection data will be prepared with a copy for both participants. In order to expedite matters, the cassettes will be packaged and sent immediately by registered mail to: Mr. Floyd Madsen, Director OSHA Laboratory 390 Wakara Way Salt Lake City, Utah 84108 The Department will send a confirming letter to Mr. Madsen requesting them to analyze the samples. He has been alerted and is expecting to receive 10-30 samples. When analysis is complete, the OSHA Laboratory will provide both participants with a copy of the results. TEST SITE AND OPERATION CRITERIA The following criteria apply to test site selection: 1. Reasonably representative of a substantial commercial use of the product. 2. Large enough to allow for several hours of dust generation. 3. Reasonably unambiguous definition of the composition of the asbestos-containing material being handled and an asbestos content in the upper part of the range of contents of interest. 4. Sandblasting will be done with regular commercial equipment and materials by a professional operator in a manner that is accepted commercial practice. UCC 013891 <7 // \ -2- \ SAMPLE COLLECTION STRATEGY As noted previously, it is intended that the Cal/OSHA and Union Carbide representatives at the site work out the most appropriate sampling strategy with the following special provisions to be met: 1. Personal breathing zone samples will be taken on the operator and the helper (if present) that are subject to the highest exposures. In addition to samples collected during the actual operations, a reasonable number of samples will be collected before and after operation to permit an estimate of the 8-hour time-weighted average exposure. 2. Area samples upwind and downwind will be taken before, during and after the dust generation operation. ADDED NOTE The Union Carbide Corporation is participating in a national round-robin study of the NIOSH collection and analytical procedure. It has been agreed that we may have an observer wearing a pair of pumps moving in the immediate vicinity of the dust generation operation. Care will be taken that there is no interference with the test. These samples will be entered into the round-robin and since they will be counted by only the standard NIOSH procedure, the results are not relevant to the present tests. SAMPLE ANALYSIS All sample cassettes will be shipped unopened to the Federal OSHA Compliance Laboratory at Salt Lake City. UCC 013892 4 oe SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento, California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York 4064!3 UCC 013893 SUMMARY AIRBORNE FIBER CONCENTRATIONS SPRAYING OF MASTICS* m Attcnwint iMLlfl >UKt L 10 SecCi yn 520 3 Tit U 3} - i arTflMP Exterior HOHOLAR MASTIC Interior Exterior - Ht MASTIC Interior Exterior cc 3 5 -- Cl MASTIC Interior exterior ALLOUAIBEE a- HOUR T ime-we IGMTEO ' AVtKAUt tArUduKL UXnl1 - (Section 5208, ntTe 3} --|--it tt it 1t ii ... l i--------- Mg. of Samlet l Asbestos by Wt. After Cure Ar Ithmet 1e - Avergo(2)^J^ * ______La_ 1.8 KAtfwiM AtLQWABLE 8-HOUR TIME-WEIGHTED^ IVERAGE EXPOS Utt l MIT (S 8-153 ) ^ Li l tf- F=f 41 (.6 14.3 NOtJs Personal Samples 1= mm 21 13.7 Oirysotlle 34.9 Asbestlrt# fiber n 30 {1) Source: Res pensc of the H. 8. Fuller Company (a "Changes In the National Emits Ion Standards for Haiardous Air Pollutants* (40 CTR. Part 61) proposed by the EPA (42 CFR No. 41, p. I2I2Z, Hare# 2, 1977). (2) Arithmetic averaue of *11 samples collected for e*ch product group. Since these operations r* generally Intermtttant, the corresponding 3-hour tlmo-uulghted averages mould be lover. A08414 UCC 013894 CT O C- O GO < > cr to C c to U WrQ-J DCroT JfEC-' <X4>> X K fc >4 <9 <9 <) a tQXoJ 03 to A o o o> cr c 9 X to L. (V J3 <9 <D C r-- oto &E xQJ C<Oo CX MS X 4-> C 0> uu c *- 0) o P> O' o g <v c X tc_ou r+pp:- <<>Cu o cr cl<x CE r | <9 >,to <9 x Cl tn 4J CT xc o 9 i-- X L. 0> rt3 OJ C *-- o a. IA X 9 <D CO a- CM CO ** o 4V->I X-O0Ji (O c 4P u o L. a. to o to 0 CM od 1 to CM oo dv to o> oo o V CM d I to o ao to to at c P to o o a) r* C1 oO M CO ov--to u f" 4P to 9 to U CO mi r-- O o to CO o CM di OCT CM O o V ov CM o O V to O oo o> to o od lt to do V f-N. o CM od v CO a> f CCS O 4J (/){/& > 4> 0 roCovCu,cf oo o*-a* * r^-- io--o OO a---- fp- r** p o (/) 1 <9 O X 0> p-* X u f to 4P CM to 1 o X to o UCC 013895 O <9 0 V> > >>P> f- <D P r-- t-r O X 4-> P> X 3 Of-- X p-r i W fu-oC4XOJ -t- c +J Io o f- <p- f- r- 3.0 4J O to u Eg o SE *cf-: v) PX <9Vo +V>14OJ 4-> -- tO H- wi*d a; O X i- -O P P<D J4ZJtt0- l(O9 C <9 -C 3 O ^ P V) O V 4) rd <o ai_c p +i^j *a r-Pjr JqjlPa>P 33 P> <D *-- C O Cr- IO QJ U <9 *r- lA P V) QJ V) <o a x x r9 -Q 4J CL 3? 3**" > to o > <9 P> f9 f-- O O 4J C 9 <4- X o u -m pi- aj id kp^ _c -r- <y ft? -*p x *-- +p 41 40 3 <9 U +-> f- Ci-C r(O-Uf p Lcl) <M -M CJ --t D Q) 3 4J c <a c a> c--- a. ( a c HJ v i/i di +/ qj o "5^0 cm a> > 01 is ^ W t- a> jQJ) tC.J>*C^- ~irn~ i- +J -c x: Ll. O --> (- to *o ^ cr PP <o 5 *O- c CU ' XA L. s (9 X i 3 cox o c tn U f- t- 41 P <9 P VIP to v> X 01 41 Oi 4P to 4- Vt C QJ <D O cD 4J E -o o O B <9 to C t/1 *r* *r <9 Q. < <-o^o 3 (O _ CM w fO 4084 !b Response of the H. B. Fuller Company to "Changes in the National Emission Standards for Hazardous Air Pollutants'' (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) UCC 013896 4 08 4 ] q H S FULLER COiVJFaNY (NfRN*rrONA<. Division -- hmtt-r. t&OOUCTS TElX 84*5)41 **0 BOX 9695 * 4835 W.G^AflO AVENUE PHil>OEcPH)A. PA 19131 * T&.EPWON6 1211)8788503 29 April 1977 '> 1 Emission Standards and Engineering Division . Environmental Protection Agency ^/..'`Research Triangle Park " V North Carolina 27711 Attention: Mr. Don R. Goodwin .'Gentlemen::...' '\ ^:..yy J ./ '^Pursuant-to the announcement (42FR41) of proposed amendments : ; to the Asbestos Standard (4QCFR Part 61), we attach herewith, ' in triplicate, factual information on the proposals, and our 'v. recommendations for. changes. vte urge strongly that action to ban spraying of all asbestos. containing materials not be taken; and that specific data be . iv'developed on potential emissions hazards of each class or type y-' of. such materials upon which to base emission controls. Yours very truly, I B FULLER' COMPANY w Y'* ' . - V* ... V t . ' J *; '/ * / - -**.V* -r7- *-y WFErebg it 4 r * : u* ff.' P. Ellis, Manager 'Foster Products International AJ ' A 0 84-1 7 UCC 013897 STATS12JT BI !.< '..IHS'H.B- FULLER COMPaNI - ' f-` *.r P.O. HJX 9o95 HilLADSLTHlA, PA 19131 r. - ... CONCERN BC FROfOSnb ro A5B3STOS STANQAED frQCrR PART 61 (h2?Rtl) Section A ' Factual Information on Specific Topics Citad in the Proposal Uia H.3. Fullar Company manufactures and sails several spray-on weather.^.barrier1213tics (thick coatings) which contain sore than. asbestos v'"" filer. Die range'of asbestos fiber content in the3* products extends Akkfrc* 1.82 to 371^ bj weight of the dry product after application. Attach! f '. ed are technical data sheets describing four such nasties (Attachment i; aa petrochemical plants and oil refineries, where they are applied on insulatad tanks, vassals, structures, structural cambers, pipes, and conduits. Scsie-of these are specific are*3 of application which, are subject to ' control in the proposed amendments. The function of asbestos fiber in our mastics is to control flow during application:: to prevent cracking during drying; to provide re-inforescent. inproved tactile strength, fire resistance, outdoor durability, and package stability. Cur Philadelphia laboratory is, and has been, engaged in a pro ject to eliminate asbestos from products such as described above. After irasaerous axcarirents we have not yet found acceptable substitutes for asbes toe in our products. 3 Technical Intact. An important technical impact resulting froa prohibiting the use of sprayon products ccntainirg sore than 12 asbestos, as proposed, would be the vithdjairtU. of xrea ther-harrier css tics froa the insulation protection market. y ho suitable replacement protective caterlals at comparable cost are yet available to provide the vater-vapor barrier function which is essential - to prevent water condensation within the insulation on low-temperature tanks ..vessels, piping and conduits. When under such adverse circumstances, thermal insulation becomes wet it loses its effectiveness* His loss increases sig nificantly the energy consumed to refrigerate process fluids and gases, and cakes the control of process tcoperatures nore difficult. .408418 UCC 013898 H.B. Fullsr Ccejany Statement ihge 2 h. Economic Ipcact. lba economic impact of the amendments, if imposed, would be to elio- ' irva.to the sale of vaather-fcarrier oastico; an aconcede hardship to cur .company, axd to other manufacturers of nasties* Salas of such nasties in v lyrfs amounted to core than one million dollars for our company alcne. toother serious economic intact would be the increased energy consumption tr, the plants concerned, because of decreased insulation effect iveness. There would be an increase in the cost of maintenance and repair of installed industrial insulation systems. Consequent to the elimination of the weather-barrier nasties production could be labor force reduction, withdrawal of manufacturing units from service, and loss of tax ratables. 5. l^agnitude of Potential Emissions. At our Philadelphia laboratory wa have- conducted a sarias of tests to detect and measure emissions of asbestos fiber during spraying of four typical weather-barrier mastics. The tests ware monitored by Steyart-Todd . Associates of thyne, Pannsylvania, an experienced firm of consulting industrial hygienists and toxicologists. A copy of the Stewart-Tcdd report is attached (Attachment 2), The overall conclusion drawn from these tests is that the eight-hour time-weighted concentrations of asbestos fiber did not exceed the current standard of 2 fibers per cc, or 10 fibers per cc ceiling limit, during the spraying of the four mastics tested. Furthermore, core than 40,000 gallons of our Konolar Mastic, which contains 2.6^ asbestos in the dry product, were applied by spraying, almost dally, over a parlcd of several months in 1976, by the 3. & J. Gallo Winery, ' Modesto, California. This mastic was applied .to the exterior insulated surfaces of wine-3borage tanks located out-of-doors in Modesto, air quality was monitored by Gallo during the mastic spray application period. Gallo determined that no detectable airborne asbestos fiber was present. (See Attachment J, Gallo letter dated April 20, 1977, which we are authorized to Include with this statement.) This field experience from a large industrial installation confirms the conclusions from the laboratory study described" in Attachment 2. 6.Friability of Srrrnv-on Materials. Qse of the criteria used In current regulations, and in the proposed amendments, is "friability4*, which is considered to give an indication of potential inhalation hazard of applied materials containing asbesths. The definition cited in Pars.graph 61.21(k) of the standard is inadequate in the technical sense because no standard method of test is referenced, by which the friJLhlgr nature of a material can fee determined with accuracy and uni formity. We believe an improved- definition and a te3t method are needed. Concerning the weather-barrier mastics described above; at no time during application or during service life are they friable. The mastics are applied in a "wet state" from a semi-fluid or paste-like consistency. After appli cation and drying by evaporation of volatile ingredients, the mastics have the form of thick, loather-like sheets or films which are not friable. . ... ' :, A84lg UCC 013899 K.b, Fuller Company btatemont rkga 3 Attached is a specimen of spray-applied Monolar Has tic (Exhibit I) which will demonstrate this points 7. Renovation or Removal of Friable Asbestos Katerials Because none of our asbestos-containing mastics is friable, there is no hazard associated with their removal where required* Section B Comments and Recommendations 1. Vfe do erdome and support the intent of the standard and of the pro posed amendments to minimize or prevent an asbestos inhalation hazard. However we believe is is not necessary to prohibit the spraying of all materials containing asbestos in excess of 1i> by weight as proposed, be cause it has not been shown that all such materials do emit asbestos fibers to the atmosphere in unsafe concentrations incident to spraying. In fact, the results of the spray testa reported in Attachments, together with the field application report of Attachment 3 show definitively that unsafe levels of asbestos'particulate matter are not produced during the spraying of the four products tested; one of which contains 3?*1 asbestos fibers. Neither do we believe it is desirable to impose the the ban, for the reasons* * of adverse technical and economic impacts described in Section a 3 and 4. It is for all these reasons that we recommend deletion from the proposed amendments of the second sentence of faragraph 61.22(e), v.'hich prohibits the use by spraying of products containing or more asbestos. 2* \fa recomsend that the phrase 'Visible emissions" be deleted from the presani standard and from the proposed amendments wherever it appears; and that it be replaced with "asbestos particulate natter", tte latter phrase specifically identifies the nature of potentially hazardous emissions. "Visible emissions" may or cay not be asbestos particulates. 3. We recommend that the first sentence of fhragraph 61.22(e) of the pro posed amendments be revised to read; "Ihere shall be no asbestos particulate natter emissions in excess of the levels established in OStia Regulations (29CFR1910.1001) to the outside air from the spray-on applications of mater ials containing more than i asbestos on a dry weight basis; except as pro vided in paragraph (f) of this section." Hiis proposed revision clearly protects the public health by limiting any asbestos emissions to acceptable concentrations. / 4. Concerning the term, friability, we recommend the development and adoption of a standard definition and a standard test method. Scistirg relevant standard tests areASd C 3*6? and A5U: C 421; but some modification of these standards is necessary to make them applicable to spray-on products. We suggest that either, or both, ASTM Committee E-6 on Performance of Building Constructions, and ASUi Committee -33 on Environmental Acoustics are technically qualified and able to develop suitable modifications of these consensus standards in cooperation with the environmental Protection Agency, UCC 013900 ^08 4-2C U.3. Fuller Conpiny Statement Age 4 We suggest further that thi3 work be coordinated by jiSTh Committee -34 on Occupational Health and Safety Aspects of Materials, Physical and Biological Agents, because Committee 3-34 is presently deep into the preparation of a comprehensive asbestos standard, 5,, Subpart B of Art 61 does not cite test protocols by which the presence and magnitude of airborne asbestos particulates from spraying operations mt* be determined. We recommend that this omission fce rectified, preferably by referencing current CShA-hlQSH procedures. 6. Finally, we urge that restrictions on spraying materials containing asbestos not be based on asbestos content, but on emission of asbestos particulate matter; whether in spray operations, or in service, or in renovation or removal activities. 7. H.3* Fuller Company offers to work 'directly with Pa Snission Standards and Engineering Division, or with other qualified standards-writing bodies such as the American Society for Testing and haterials (ASH), to implement the suggestions and recosaendations made `herein. Will we provide gladly any pertinent, non-confidential data on our products, and also the expertise of long experience with their spray application. 29 April. 1977 Prepared by v/.P 2Llis ^ UCC 013901 < rt <*. AN EVALUATION OF POSSIBLE.AIRBORNE ASBESTOS.EXPOSURE FROM WEATHER-BARRIER MASTICS MANUFACTURED BY THE H. P. FULLER COMPANY, INC. * Arthur Nel1 son Industrial Hygfem'st Hay, 1977 UCC 013902 <sci C'TlCn TABLE OF CONTENTS 4 I. INTRODUCTION II. SUMMARY III. METHOD OF SURVEY IV. TEST RESULTS AND PHOTO MICROGRAPHS V. ANALYTICAL PROCEDURES VI. SURVEY PHOTOGRAPHS AND DIAGRAMS VII. TECHNICAL PRODUCT DATA SHEETS VIII. PRODUCT TECHNICAL INFORMATION IX. CURRICULUM VITAE 4 UCC 013903 c-rtc. I. INTRODUCTION Recent proposed standards by the EPA regarding airborne asbestos con centrations in materials containing more than one percent asbestos have caused a degree of concern to manufacturers of Weather-Sarrier Mastics for insulation and roofing materials. The standard as proposed, would preclude the use of these compounds if the material has more than one percent of asbestos. In order to ascertain both environmental and occupational exposures from these materials where the concentration of asbestos anthroboles exceed one percent, a protocol was developed establishing methodology to determine airborne concentrations of asbestos fiber during the spraying application of four (4) representative H,B. Fuller Company Inc. Mastics. Four compounds with concentrations of asbestos varying from 1.8 to 34S bound in asphalt hydrocarbons or vinyl acetate water base products were utilised. Spraying of these materials was done under two sets of conditions; in .a closed room simulating interior usage and outside in the ambient 'air, simulating roof application or outdoor insulating techniques. The testing was accomplished on two separate days, April 19 and 20, 1977. UCC 013904 Page 2 II. SUMMARY A total of 36 samples Including controls, were taken for determination of airborne asbestos fiber concentration. Sample times ranged from 10 to 42 minutes. Fiber concentrations were reported using standard laboratory techniques as established by NIOSH {see analytical procedures for detailed procedures used and calculations). <xr Based upon the current occupational standard of 2 fibers/cc for an 8hour workday and a ceiling value of 10 fibers/cc for any 15-minute ; concentration, all of the test spraying application were well below standard. Concentrations ranged from .5 to less than .002 fibers/cc and it should be noted that in many instances that fiber counts are in reality, below detectable limits. 4 UCC 013905 cia./e<Lt <rtc. Pa ge*"J k III. METHOD OF SURVEY Airborne asbestos samples were obtained utilizing Mine Safety Appliance Gravimetric Sampling Pumps and M111ipore Gast Type Continuous Duty Pumps with appropriate critical orflces. Samples were taken on openfaced mlllipore filter type AA, 0.08 micron, and pumps were calibrated before and after survey utilizing; a Universal Pump Calibrator in the case of the MSA Model G's and an NBS Certified Wet Test Meter for the Gast Type Pumps. Area and personal sampling was accomplished. The first day's data was obtained while spraying was performed on sheets of paper approximately 4 x 15 feet in length attached to the interior v/alls of a suitable workroom. Spraying was accomplished by utilizing normal industrially accepted practices as recommended by the manufacturer. Nozzle pressure averaged 2000 PSI. Area sampling was done at strategically located points in order to obtain maximum coverage and capture maximum concentrations of airborne contaminants. In addition, In each application, the operator's breathing zone was also sampled. ` Exterior environmental sampling was accomplished utilizing the same equipment; however, spraying was accomplished on three (3) 4 x 8 sheets of plywood, positioned against an exterior wall. In addition to the vertical characterization, a horizontal spraying operation was done on the ground. Paper was laid out In approximately 30 foot strips. Weather conditions for these tests were as follows: ambient temperature 64 degrees F. to 70 degrees F.; wind was from the North, 3-5 miles per hour. Area sampling was accomplished and all sampling stations down wind of the spray operations In order to obtain maximum fiber concen trations. ft UCC 013906 C'fXC * IV. TEST RESULTS AND PHOTO MICROGRAPHS JT" 4' UCC 013907 : i-.-. * 7.7 . if u * .r>>; >>v;;':= fv`; o(J u/ CO *. p-_ :?.*r !;# ; . \M . * ^7' fv '.`i-V.- . . - . : - ' * ,, 'Cl-!. *sr:.: '-..r- . .1 ` Page 5 . . V. . o CO <o O (O CO cKO CO r-- 00 r-- Q pd vo vo 10 10 ' ' uo OlL/US) CO .E ON co CO W CM o O O O f-- CM `0 \ - ' -':-V ^ cin* ' UJ CO m m cn m oo oo i-- CM ^ r- r-- < XX X X X cm cm cm cjd pd o fO n n N r-- - - > ' 'r CO CO ao <r P*. kj to m co ao CM m * 00 to to v--' m on on on m r-- 2_^r V' ^' V Jvi O C3 ,\ r-~ 00 o * <M o CM M <5k V' CO VO C\J VO O w to 'ir . -: ' ; co o X en to o * 1" X trt 4/1 CM -1 fO ... - . ; CO o o f-- X tn X PD PD ooo . r- r-- XX tn now ` / 1 -4 . ps* ^ r** io co tn 0^-000 *r ..:' ' ; * .: ; ! c----r*'.-' . . . v , S UauJj a. tn ,, <0 e o 4> Of 4J S- 4> ft-Uft-OJU C C O. c <c w tm at** o ce cc <9 ) (O v L >> > ^ O CO o* a> ro r-- <v < c | *-- M W O /* X, ZVO^M (/)WJ3 id 00 ao co r^. CD O o r r ** ' '* .T . . .*''; ' ' ' *f ' > /O c o 4 *Hr tn 01 to ^ co ao p. n to rCO tn to ON *T to V to to O' (SfSfSCNtO <A.0M_ Cb. Ci o' <s i-- jjo ttMOOO Or--,-- O O * coco coco oa ooo rmm XXX X X CM tfivctort # <oav/-r-vo CM CO VD *-- oo CD CD pH CO o ud o o o *9 S O lO |Q (Q tn a> oj a> qj 5- L. S- u i. -v. V. i-- O CD 1-- O <JJ r-- c > o cm vi a O O tn ^ x cl X to W.V*- UJ <c A 0 8 428 UCC 013908 Page 6 :\Vf y . u; & :* *: TABLE I.(c o n tin u e d ) Oo toeoNcoio p wCODOnUtfH<OAvrr~IO^A rfO** fc- f` * . -.! ` N ^ M ^ -4 ^O ^^ 9 MvvV *oT < K oo \ Voom roov*jVoo*j A\ Av A' a* min O ulifl O<fclNo^W,ofort' r~. r-~ to cn CM CM CM CM CM *, '. r jt aaoo m o> vo rcvoo- ccC^Moi rros-> o rq--o V* % ^* ' . .* rLO^ pLO* oLO*. pL-O cU-O* o o o o o A. ^ t V- V v * - *' n tn n to co i-- co r--* O O O , 00 CO CO CO OOoo a: co CO X X X X u. ^OU3*UM OVO fas x </</></>/ M V) (A VI V) * oj a; #'rr~ ^ *" co cn ro io-- ro-- ro* CO XX CO X OlOlO^OU* X lO <c/A1 CIA/I X V0 C(A/1 4). CJ Of CO rO-- CO CO CO X 0 0 0^0 r-- f" r-- XXX VI CM* U0 CM (y (Or- Ol r- . <1/1 ui a. Cl. X to ucoicinoccodrcsoFco* boooo r . ; ... ."*.'** " '* ' ms C (oVO iaiQ-i |aUQi Uv. (uo4A} <<<<o- . . *-.'t* ''* * ' * ^ p*. CO CO CO ps* tr> ro o> co OOOOO * *r <r -/* '' . : '\*'*'.* ' '' ' '.V . * *: .'.V' y.. *. -V " ," - ac <9 fl IQ VoI 4w) <i-D QwJ 4u1 a> < C C < a. t*' .'... . ctOn mrOlO<fOn "rOoor ^a o "ow >a */ ' *C9 |Q f(J fl (Q OH <(^I <oS. <oL<oU&t4*) ; *'! / , ' *2 ****n 4> to Mj c ^ o o u ov V L ^vtOi rs> c<1> o U^ OE MO*>- L<1.> r-- 3 ** o1 *(V** oVt ^X Q. *0 ' * !* s ` V J. V .1 r ' *v 01 Go Of c_ +O>) Vm2I O 19 J3 U 4- -J o p*v. a> i0-*y0- -4r-- | (o\1 +IQJ 4o4j a OSjXX ai <o .. .JP\. y.'. *' "* vOff cO oH -Q* V. *4-^ V(IQA P% W0> *o1*^U Di V4V a mo $ x a X co W- 01 <9 UCC 013909 oO ' <d o "Oc<a t/i at>-- .q +or-c>j O 0*1 tn ja a; jd co -o<ao E uu </) * s~ <a -<QU "OO e a: <Co/> CD :n Oa> CO oOu ^co 01 "Ocu fCs-M- OQafc.i I 01 29 trie. Page 7 TABLE II Bulk Sample Asbestos Type and Percentage Analysis by X-ray Diffraction. MY Cl Mastic 4r8IT 39-?fr ^ <3 HI Mastic 38X chrysotile 34X amosite (anthopolite) 13% chrysotile Monolar Mastic -2,844- 60-36 Lagtone Coating K.-et 3o--po v. r ,, No detectable asbestos. Small talc peak. No detectable asbestos. Jf ^ **\ "t6 ~ff\ rrccJ'/'^ 5 st^yryf fry ///7^/70. fl'j}. nlurpiL, UCC 013910 >0`3o h Tt/sicc SVc* Ytn 6 fr i.L A Ootsios. Sf**V gc.. uJAl.l VavcAi. <y UCC01391I f* \ I * Yi'li'r J . t n < Page >'b | '}:>> S:- >. ' & i\.\i-;^:: .;'!% *"' ' V;" V.'.;' ', a ?:;Vf f Ir,V: .'- tf.. ,/ii '..>. t-'i'...-? ?> .ij.'i?54:^! Fig 1 and 2 (above) Sample 3538 (400X Maani ficati*>) Fig 3 (below) Sample 4031 (400X Magnification) / # UCC 013912 4a< 7/, > /- / t* v /*f J Page Pc Fig. 4 (above-left) Sample 4037 - 400X Magnification Fig. 5 (above-right) Sample 4057 - 400X Magnification Fig. 6 (below) Sample 4063 - 400X Magnification UCC 013913 Fig. 7 (above-left) Sample 4075 - 400X Magnification Fig. 8 (above-right) Sample 4078 - 4C0X Magnification Fig. 9 (below) Sample 4038 - 400X Magnification UCC 013914 i,;v%; 34 c-nc. Page 9 V. ANALYTICAL PROCEDURES Enumeration of Asbestos Dust on Membrane Filters Apparatus and Reagents 1. Mixture of Diethyl Oxalate + Dimethyl Phthalate; 50-50 mixture, mixed In a large graduated cylinder, 2. 0.14 grams of mllllpore filter type MF with pores >0.8u Is used per 2 ml of solution. This produces a viscous solution having an index of refraction of 1.4? (slightly below that of asbestos fiber). Procedure A drop of this mounting Is placed on a microscope slide and a wedge of membrane-filter usually 1cm x 2 cm is placed on the drop, and # 1.5 coversllp placed on top. This is allowed to stand 15 to 25 minutes, while the filter clears. All glassware used should be thoroughly rinsed in double-distilled water, and dried with low lint paper. All samples should be counted within 24 hours for uniformity. The fibers tend to migrate to the edges of the cover slip with time. (1) Annals of Occupational Hygiene, Pergamon Press, Vol. II, 1968. UCC 013915 c-rte. Page 10 Optical System Phase contrast microscope--------'4mm hldry acromatlc lens and lOx ocular with a portion reticle mounted stationary left or right ocular, depen ding on the microscope, at the level the limiting diaphram should be used. The left half of the reticle should be calibrated according to the formula of: In microns: L x 2n n= porton dot number. Limits of visibility with this system are around 0.3 microns and the resolving power for differences is about 0.5 microns. Tt is recommended that counting be done by categories according to the porton reticle with the number 1 dot usually being around 1 micron. Thus the category will Include all fibers with diameters less than one micron rather than stating the exact diameter, e.g. 0.5 microns. The Illumination for this system should be on a ribbon filament illuminator adjusted to Kohler Illumination and a green filter with a neutral density of 0.9. Counting Technique At least 20 fields should be observed. All of the fibers longer than 5 microns counted. Because some clients may wish all the fibers to be counted It ts wise to set up a category for total fibers, i.e., all fibers having an aspect ratio of at least 3 to 1. After counting has been completed, the following formula Is used to compute the flbers/cc concentration: Fibers/cc =* irr2n L*nV where: *1*2 * area of membrane L# area of microscopic field obtained by stage micrometer N a numbers of fibers observed n number of fields observed V volume of air In cc A UCC 013916 i APPLICATION CONSISTENCY (ASTM D2507-70) Brush or spray WEIGHT PER U.S. GALLON (ASTM Dl475-60) 11.4 pounds (1.4 kg/liter) AVERAGE NON-VOLATILE (ASTM C461-64) 43% to 44% by volume (depending on color selected) THICKNESS ANO COVERAGE (FSTM 71) Dry Thickness: 0.017 to 0.007 inch (.43 to .18mm) Equivalent Wei Coverage: 0.032 inch to 0.016 inch (.81 to .41 mm), 50 to 100 sq. ft. per gallon (1.2 to 2.5mJ/liter) on smooth non-porous surfaces. Porous or rough surfaces may require higher gaiionage to attain required dry thickness. DRYING TIME (ASTM C461-64) Touch: 1 hour Through: 4 hours SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) Minus 50F to 180F (minus 46C to 82C) WATER VAPOR TRANSMISSION (ASTM 96*66) 3.0 perms at 0.028 in. dry thickness SAFETY * Wet Flammability (ASTM D93-72) Non-flammable Dry Flame Spread (ASTM E84-70) 30 on 1/4 in. Asbestos Cement Board (The flame spread may vary at different product thicknesses and/or when applied over surfaces other than asbestos cement board.) FOSTfeR LAGTONE COATING is an emulsion type poly meric protective coating. It forms a tough, flexible finish which can be used on all types of thermal insulation, in cluding the expanded polystyrene and polyurethane foam insulations. Use LACTONE COATING as a combination adhesive and coating for cementing and sealing light weight factory ap plied fabrics such as 8 ounce canvas or muslin. Use LACTONE COATING over hard asphalt weathercoats to provide color and additional weather resistance. Some flame spread resistance is added to an insulation system when LACTONE COATING is applied in 2 coats with 20 X 20 white dass cloth over existing asphalt weath er-coats. LAGTONE COATING is suitable for coating over asbestos-cement board and masonry to blend with ad jacent coated insulations. LAGTONE COATINGS are resistant to dilute acids and alkalies, solvents, and water. They have a mild odor during application. 30-70 and 31-90 comply with Rule 66 for Los Angeles County Air Pollution Control District. LIMITATIONS Protect from freezing. Do not apply below 40F (4C) or above J00F (38C). Do not apply over other paints. Cer tain soft asphalt mastics papers or fabrics saturated with asphalt may bleed. These products are classified by Underwriters' Laboratories, Inc. FSTM: Foatar Standard Text Mattiod Tradamarfc 10/74*1 t-5M BFN-tBB; BRXVS/622: LFN-1113 H.J 8. FULLER COMPANY FOSTER PRODUCTS 5220 Men Street N.E. Minneapolis, Minnesota 55421 UCC 013917 4c? < a> IMPOMTAtfr--UMfTTO WJUWMfTY -- 7Ht InfbrtoMto* M* (M 'MliM to ifrtt bvUlfto ito r*mt to ttto best ** evr b*owttf9t M Tito rK0nitoJ(ini 4*4 V* reM* ' '*''*.'.1:10* ** to tov.it* Wr ftc*toto*4 Mtof ***4tf# tut* 99 j*i|# bp in* pure***#* to tofwMttni is *wps#4 bp *>. w himm m luatHty cm it Wf vim* 9ir tcctpIS Uto "t to ' Mi aiUtovf urf olitof o itrjrtiw r COLOR Jotter c. I. MASTIC Is a tough, Black durable vapor barrier asphaltic APPLICATION CONSISTENCY 60-25 Trowel 60-26 Spray 60-28 Spray(Low Temperature Grade) coating. Became of its flexibility and low vapor permeance, it is an Ideal surface coating for low tem perature Insulating applications where the insulation used is not HEIGHT PER U.S. GALLON(ASTU D1475-60) affected by mild solvents. 0.3 to 9.5 pounds (1.12 to 1.14 kg/lltre) C.I, MASTIC aay be used on heated AVERAGE NON-VOLATILE (A2TH C461-60) lines, vessels and equipment in 64% by volume (60-25 t> 60-26) intermittent or dual temperature 58% by volume (60-23) service to prevent the entrance of THICKNESS U COVERAGE (FSTM 71) (Subject to nature of material being coated). Pet coverages shown below are for smooth non-porous~surfaces. Porous or rough surfaces any require higher gallonage to attain required dry thickness. TACK COAT: 60-25, 60-26 water vapor into the insulation during off periods or on cold cycles Porous, dusty insulation surfaces should be primed with STACXFAS Concrete Curing Agent 51-06 prior to application of mastic. Insulation must be dry before mastic applica tion. Pry Thickness: 0.020 to 0.041 inch C.I. HASTIC is an effective protec (0.5 to 1.0 ma) tive coating for metal. Priming is Equivalent Pet Coverage: 0.031 to not necessary but adequate surface 0.0625 lach(0.8 to 1.6 =a>, 2 to 4 preparation is always desirable to gal. per 100 sq.ft.(0.3 to 1.6 liter/m1)obtain optimum results. A coat of- on smooth non-porous surface.. as industrial oside-chromate primer FINISH COAT: 60-25, 60-26 will prevent spread of rust from Dry Thickness: 0.061 to 0.081 inch points of physical damage. C. I. MASTIC 60-25 may be used as \' gal. per 100 sq.ft.(2.4 to 3.2 liter/a3;) pip d dUct insulation* on smooth non-porous surface. C.I. MASTIC 60-25 meets the require MOTS; 60-23 Use 10% more material for ments for water proofing nasties in equivalent dry thickness. the TRI-SERVICE SPECIFICATION for PRYING Tilts (ASTU C461-64) Touch: 1/2 to 6 hours , UNDERGROUND HEAT DISTRIBUTION CON DUIT SYSTEMS. Through: 36 hours C.I. MASTICS 60-25 and 60-26 meet SERVICE TEMPERATURE LIMITS(FSTM 70) Military Specification UIL-C-82052. (Temperature at coated surf ace) Minus 20T to 200F(-29C to 33C) LIMITATIONS Do not use-in food storage applica RATER VAPOR TRAHSHISSI0N(ASTH E36-66) 0.00 Perm at 1/t) inch dry film thickness (0.00 metric perm at 3.2 cm) HAZARD tions whore odor might affect food flavors and tastes. Do not use on polystyrene foam. Allow at least 30 days curing before top coating with water baa* coatings. Vet Flammability (ASTU D93-73) Flash Point i00? (38C) Surface Flame Sereadfdry)(ASTU E162-67) FOR INDUSTRIAL USE ONLY BT TRAINED AND QUALIFIED CRAFTSMEN. 145 on 1/4 lncb(0.63 cm) asbestos cement board. (The flame spread may vary at different 408438 product thicknesses aod/or when applied over surfaces other then asbestos cement board.) AH >.* Threshold Limit Value for solvent vapor (FSTU 73) T.L.V. 100 ppm UCC 013918 ;OSTER DIVISION kMCHEM PRODUCTS, INC. kMBLER, PA. 19002 71# ixiwmiw wl tot* NBtiM towto it* tot*# w*#to* *# ***** to***to * to rtUaft**. iipivual # ]*!*. ii itif imm *1 than acttf*6v *"# tt* prodwef* --dCffe# if* Ml# uritoni vmtaiy, (>< 1* th* MtUpitirv(toir up*. ap#licj*a or pff*nnanM. I>* FuicAliar M*/to vur M**ll h* toto 1***1 iRfnnf* MUlHlf MOhll, HUM *1 IM piMWtl < Ito (**'* *** "*lock pr*0#Ct lot hi* pu/?*m >n# fc* tUitoMM t**t*ito# Mfttft Vtolt to ICMUM*# to "'#`*****1 > itUlM# amt virr to##*"# ou# MtJto# to# c*Ml>ito* ## r p*1*11 (7 to #r#(ic*u t*cjtov *# **v*k* whrert tufflM to toW*> to* ii"**ntof raetto* * IM p*r*ir^toc* ll to/ #f*#tott. UtovlM * c*/i**I *ftf*rcp m* m*n*e/>d*tito# *Ihc * m*M ctof**n# * *+ to* #r*#to. lh*f*M v* MU It * Ctot'llto *i Ml* 1MI wWl ftMir iMIWtll to flto# 1U ******** ***** *f to# ftolto t'tovCt fi**# U to< ((kHitsuti to to wtuun W *H* ** ** *t tollMTf. tot Out iito<M to 'UMify iT--i / \ 1k--L-*f. COA TINGS SEALANTS ADHESIVES <-- PRODUCT DA TA CaQkAr.~'=!o,r'r f.kvjp tv.i.?* i,c ,r'* !*vt>.irm("aoimi l J PROPERTIES COLOR 60-36 White (Spray) 60-29 Gray (Spray) 60-61 Black (Spray) Other colors available on special order FOSTER MONOLAR MASTICS APPLICATION CONSISTENCY Rubber glove, trowel or spray WEIGHT PER U.S. GALLON (ASTM D147S60) 9.3 to 9.7 pounds (1.11-1.16 kg/Iiter) AVERAGE NON-VOLATILE (ASTM C461-4) 30% by volume THICKNESS AND COVERAGE (FSTM 71) (Subject to type of surface being coated) Total Dry Thickness: 0-030 inch (0.76 mm) minimum Equivalent Wet Coverage: 0.096 inch (2.4 mm) (6 gal./lOO ft1) (2.44 liter/m2} on smooth, nonporous surface. Porous or rough surfaces may require higher gallonage to attain required dry thickness. See Guide Specification for detailed recommendations. - DRYING TIME (ASTM C461-64) Touch: 3 hours Through: 2 days SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) Minus 20F to 250F (Minus 29C to 121C) FOSTER MONOLAR Mastic based on duPont Hypafon is a tough, flexible, fire-resistive finish for protection of thermal insulation. It is also used as a vapor barrier coating for fittings. It is excellent for indoor or outdoor use where chemical resistance and durability are required. SPRAYED POLYURETHANE FOAM INSULATION Foster MONO LA R Mastic provides outstanding weather barrier and vapor barrier protection for sprayed polyure thane foam in outdoor locations. It is a one-component high film strength product, usually applied in a single coat with standard airless spray equ^^nent. Consult the MONOLAR Brochure and Guide Specifications for further information. APPROVALS: Underwriters' Laboratories, Inc., Classified, UL 732 Be UL 790. ICSO Report No. 2763. LIMITATIONS Do not store over 100F (38 C). Do not apply below 40 F (4C) or above 1QQF (38C). Usa within six months for best application properties. WATER VAPOR TRANSMISSION (ASTM E398-70) 0.0S perm at 30 mils dry (0.05 metric perm) HAZARD Wet Flammability (ASTM D93-73) Flash Point 100F (38 C) Dry Flame Spread (ASTM E84-70) 20 on 14 in. Asbestos Cement Board (The flame spread may vary at different product thicknesses and/or when applied over surfaces other than asbestos cement board.) Threshold Limit Value for solvent vapor (FSTM 73) T.L.V. 100 ppm Some plastic foams may be attacked by the solvent in this product. The user should establish by his own test that this will not occur. Wet or uncured MONOLAR Mastic may be discolored by sulphide atmospheres, but the discoloration will bleach out after exposure to sunlight. Avoid crushing cellular glass when troweling on MONOLAR Mastic. FSTM: Fovtar Standard Tat Mathod ^Trademark of HB Fullar Co. 7/75-12 LFN 870/S71 FOR INDUSTRIAL USE ONLY BY TRAINED AND QUALIFIED CRAFTSMEN H. *B. FULLER COMPANY FOSTER PRODUCTS 5220 Mam Street N.E. Minneapolis, Minnesota 55421 800-178.7107 UCC 0)39-19 408439 /IIWTAjrr--UUtrtB WAJUVtrr -- V* Watmtfim mt ftMM CO* > AM* AvtUffrt If# ft bttt if BN ttm. TN `tCBPWNNaiMhi N ; uQgrshcn* cowliitrf &**** *# * W# vrlfttul Cut#*' 1 ** (tpttstr.tjfte* *5 r# Wt rKtNNM tint tttttutt mil tt na By imfctu*.** x* ^tl * preiwct r i*w for twncti *jrps afii MB. 0m tHy b<H)a<rM Still 0* ( <rCI Of Ctf iif am ft#frr| 9fVf <('<* Bf BH* .BtftMfV - Mf *1' fAH * hit p*o*. SnN ijif paifLMst pK* o< ifutfiiitt sudtuej 6* ns. * ustflw nt tiafrtJalv `tr ftJfti^ts rf toy *3 *1 irt Str BCCfftf (Bt trotvtl M tt ' BN uy rspmB tr V. ftuTO-rasnr PROPERTIES COATINGS SEALANTS ADHESIVES ^=Vo -- >1 -S'lK-l,' ~4-""2'^^.y..r.truit=.*-- FOSTER H. 1. MASTIC COLOR (FSTM 4) Black APPLICATION CONSISTENCY Trowel or spray WEIGHT PER U. S. GALLON (ASTM Dl 475-60) 9.4 pounds (1.13 kg/liter) (Average) AVERAGE NON-VOLATILE (ASTM C461-64) 40% to 45% by volume THICKNESS 4. COVERAGE (FSTM 71) (Subject to nature of material being coated). Wet coverages shown beiow are for smooth non-porous surfaces. Porous ot rough surfaces may require higher gailonage to attain required dry thickness. Dry Thickness: 0.080 to 0.106 inch (2.0 to 2.7 mm) Equivalent Wet Coverage: 0.19 in. to 0.250 in. (4.8 to 6.4 mm) (12 to 16 gallons per tOO sq. ft.) on smooth non-porous surface. Tack Coaii Dry Thickness: 0.040 to 0.QS3 inch Equivalent Wet Coverage: 0.094 in. to 0.125 in. (6 to 8 gallons per 100 sq. ft.) on smooth non-porous surface. Finish Coat: Dry Thickness: 0.040 to 0.053 inch Equivalent Wet Coverage: 0.094 in. to 0.125 in. (6 to 8 gallons per 100 sq. ft.) on smooth non-porous surface. FOSTER II. I. MASTIC is a highly durable, protective weather coat for use over thermal insulation where an economical breathing mastic is required. H. 1. MASTIC* is a fibrated asphalt emulsion, made from a blend of prime asphalts, special colloidal clay filler, and carefully viewed asbestos fibers, which will not shrink or crack (particularly at the critical right angle bends) during curing. It has exceptional weathering stability and develops with its final set a firm, durable surface with good resistance to acids, alkalies, abrasion, and other abuses typical of outdoor industrial conditions. It has no heat flow, remaining hard and stable under ail normal operating temperatures. The following grades are available: 90-07 H. I. Mastic (Standard) 90-10 H. 1. Mastic, Low Temperature Grade U-S-D.A. (M.l.D.) chemically acceptable. 90-07 and 90-10 comply with Rule 66, Los Angeles Air Pollu tes Control District. LOW TEMPERATURE GRADE H. 1. MASTIC 90-10 may be applied during freezing weather when temperature is above 20*F (minus 6.7*0. LIMITATIONS (Standard Grade only) Protect H. I. Mastic from freezing in storage. Exposure to severe freezing conditions during application, or between application and full cure, may cause cracks in the cured film. DRYING TIME (ASTM C461-64) 9Ot07t Toochr I hour at 73F (22.8*0 Throaglu 8 hours at 73F (22.8*0 90-10: Touch: 8 hours at 60*F (I5.6*C) 24 hours at 20*F (minus 6.7*0 Through: 7 days st 20F (minus 6.7*0 As with all asphalt emulsion products, application over insulations containing soluble salts may show efflorescence or white salt deposits on the surface if water is present in the. insulation. Efflorescence may be removed by normal rainfall or washing after mastic is dry but may recur if water con tinues to be present in the insulation. ' SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) 0*F to 200*F (minus 17.8'C to 93.3*0 WATER VAPOR TRANSMISSION (ASTM E96-66) 3.0 perms (min.) at 1/8 in. dry film thickness (2.0 metric perms at 3.2 mm) HAZARD Wet Flammability (ASTM D93-73) No flash to boiling <210"F, 99*0 Dry Flame Spread (ASTM E162-67) 135 on Vi in. Asbestos Cement Board (The flame spread may vary at different product thick nesses and/or when applied over surfaces other than asbestos cement board.) # Tfdwntrk FSTM-- Fottvr 5tnara T##t Method Form No. 3155-270 4/76-12-8F-243, 268; 9f 0-953, 954 LFN-tltO, 1112 FOR INDUSTRIAL USE ONLY BTTRAINED AND QUALIFIED CRAFTSMEN A8uc J H..B. FULLER COMPANY FOSTER PRODUCTS 5220 Main Street N.E. Minneapolis, Minnesota 55421 800-328-7307 UCC 013920 IMWSTAR1--UttITtO WAAAAnTt -- If* taesuttM AM UU nnttt. M In tMt Midi* Mr ivm! It Hit tr;1 ri lut kimlMgt ftsjj. U\9 fecoi.vmoftdiliont *nA juQOMliW** cq*I*a4 ft* in* l't md# vutottl V f*0t**' tin* 85 !d ifunls Wew. miHli9MrUMr 'hit Killftb#('Mnmat*i *m* tt*ftre Ipt*frc***Mt*rf { il *r w . .Uftld 'or *m!*e''<var#ftMd #Uju/?wn arw? sn IUmt Ud ift* puwc1r8u>j*d(WwK#iU*wtrtmw*ri*nn*twi*r tu4ofvitmA(iic8.%. ip*,<SMi#itntnmerzu,\rtt.luomi, ttt 6mgn ti idy u*4 tat [tit fhiNt^ it L'.xA. E. & . >i ' J. GALLO WINERY Califtrni* April 20, 1977 Mr, Irving Steltz Foster Division H. S. Fuller Company P.0. Box 625 Spring House, PA 19477 Dear Irv: Attached is an outline of the asbestos'test which I described to you over the telephone on April 14. We could not find any airborne fibres using this method. Equipment Used: Bendix battery operated air pump. Procedure: 1. Set at 1.8 to 2 liters per minute. 2. Run for one hour. 3. Observe membrane under microscope using Light Field Technique. 4. Count glowing particles. ; Presently the Federal Regulation allows 2 fibres per cc of air; however, a new Regulation is pending which does not permit more than 0.5 fibres per cc of air. Sincerely yours. E. & 0. GALLO WINERY Donald C. Bettencourt Manager - Cellar Operations DC8:jp 1 ?5Aor'7 711 S UCC 013921 SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN.THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY.SB-1591 Airborne Asbestos Concentrations from the Grinding of Thermoset Resins Containing O.B-18% by Height Chrysotile Asbestos Prepared for the Occupational Safety and Health Standards Board Sacramento, California November 15, 1978 Prepared By Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013922 SUMMARY Union Carbide Corporation has published the results of a study of methods to detect chrysotile asbestos in the airborne dust generated during the grinding of thermosetting resins. As a part of this study, resin plaques containing 0.8 to 18% by weight of asbestos were abraided with a powered disc grinder. The operation was carried out in a closed, 8-1/2' x 8-1/2' x 8' room. Airborne dust samples were collected and counted by the standard NIOSH/OSHA procedure. The personal samples showed concentrations ranging from 0.0-0.7 fiber/cc >5u and the area samples varied from 0.0-1.2 fiber/cc >5y. There was no relation ship between the asbestos content of the plaque and the airborne asbestos content that resulted from grinding. These data are a small part of an extensive study, the balance of which is not related to the Standards Board hearing. In order to provide convenient reference, the relevant portions of the paper have been assembled on the following page. A complete copy of the paper is also attached. UCC 013923 A08443 Defection of Chrysotile Asbestos in Airborne Dust from Thermosetting Resin Grinding REFERENCE: Feulrin*. C. M.. Foreeri*. W. D., Kleber. E. J.. and Rhode:. H. B.. "Detection of Chryaotite Aabeatoa lo Wrborna Dual from Thrrmojrtilnl* Resin CrlndlnJournal of Tasting and Evaluation, JTEVA. Vol. 3, No* 6, Nov, 1975, pp. 482-490. Sample Preparation and Description Resin plaques containing 0.8 to 18% chrysotile were ground with a power-driven hand grinder equipped with a 7-in. (177.8mm) diameter, 16-grit abrasive disk simulating the fabrication operations found in boat yards and the automobile industry. Compositions of the plaques are listed in Table 1. The grinding was carried out in a thoroughly cleaned, closed, 8H by by 8-ft (2.6 by 2.6 by 2.4-m) room. Tha plaque, approximately 3^-in. (32.7-mm) thick by 3 by 2 ft (0.3 by 0.6 m), was clamped to a bench 30 in. (76.2 mm) from the floor approximately in the center of the room. The edge was ground for a period of 4-5 min with the grinder rotating in a direction to throw the heavy particles toward the floor. In addition, individual samples were collected before, during, and after each grinding operation by aspirating at the rale of 2 litres per min through Type AA membrane filters (0.8 pore size). TABLE 1--Com portlionj 0/ ckrVtoiilt-betLrinu pla/ju**. Sample No. Retin Weight. Typo % CbrysotH# Weight, Type- % Fiber Glass Weight, % Sin] Weight, % Lime stone Weight, % 1 polyester 79.2 JlG-244 0.8 20.0 2 potyciter 99.2 RC-244 0.8 ... 3 polyester 93.0 RG-244 2.0 4 polyester 98.0 RC-244 4.0 A epoiy 76.0 UC-144 4.0 20.0 .,,..4 ...... 0 polyester 38.0 FtC-110 5.0 20.0 10.0 40.0 7 poiycatcr 38.0 RC-no 10.0 10.0 10.0 35.0 ...8 polyester 30.0 SC-200 18.0 2.0 50.0 Tyi*w ftC-t 10 and JtG-144 &rc opened fiber*; SG-200, pcltctiicd; KC-244. silica routed (Union Carbide Corporation designations of reSued California chrysolite, cummcrcml product*}. before during during* miter No. fibers/cm* of sir 0 0 00 0.01 0 00 0.01 0.2 0 0.01 0.01 1.2 0.7 0.02 0.00 0.1 0.1 0.05 0 1.2 0,8 0.02 0 0 00 0.03 0.9 0.3 0.08 ^ l ~ * ------. aTJ"0ST4 4 UCC 013924 TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento, California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013925 J SUMMARY AMD CONCLUSIONS In 1974 a bill prohibiting the spraying, after July 1976, of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair was passed by the legislature. A single exception, for cold process cutback asphaltic roof coatings, was provided. A second bill, enacted in 1976, provided a two-year exemption from the ban for Portland cement plaster containing less than one-half of one percent asbestos and for certain products similar to cold-process cutback asphaltic roof coatings which contained encapsulated asbestos fibers bound within the finished product from manufacture through application. Finally, a third bill (SB-1591) was adopted this year which directs the Occupational Safety and Health Standards Board to consider whether exemptions should be continued and, if so, to promulgate appropriate regulations. This presentation addresses only the questions in the Notice of Hearing which relate to asphaltic coatings and products with encapsulated fibers. The widespread uses and valuable contributions made by the products are described. Airborne asbestos fiber concentrations are presented from 34 locations covering spraying, removal, and abrasion operations for a variety of products. These data demonstrate that the ceiling concentrations are far below the 10 fiber/cc >5u allowed, and the time-weighted average concen trations are well below the more stringent maximum limit of 1 fiber/cc >5y imposed by SB-1591. Documentation is presented that extensive and generally unsuccessful efforts have been made to find substitutes for asbestos. It is also shown that the value of the products affected is about $9,000,000 per year, so the economic impact of a ban would be substantial. On the basis that these products are useful and valuable to our society, that the potential worker exposures have been shown to be well within the limits specified by SB-1591 (as well as within the limits permitted for other nonsprayed asbestos-containing products under present DOSHA Asbestos Regulations), that there are no suitable substitutes generally available, and that the economic effect of a ban would be substantial, it is requested that the continued use of asphaltic-based coatings and other products containing encapsulated asbestos fibers be permitted. Specific wording suggesting a maximum allowable TWA exposure of 1 fiber/cc >5u and incorporating the other provisions of SB-1591 into Section 5208, Title 8 is presented for consideration by the Standards Board. UCC 013926 4 TABLE OF CONTENTS ____________ ______Section A. BACKGROUND. . . .................................................................... B. SCOPE OF THIS PRESENTATION.............................................. C. PRODUCT USE INFORMATION .................................................. a) Roof Coatings..................................... ........................ b) High-Performance and Specialty Industrial and Trade Coatings and Laminating Resins................. D. AVAILABILITY OF SUBSTITUTE MATERIALS......................... E. WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS . . . a) Sources of Exposure Data. . ......................... .... . b) Presentation of Results .......................................... c) Discussion of Results .............................................. F. BASIS FOR CONTINUED USE OF PRODUCTS ......................... G. SUGGESTED CHANGES IN SECTION 5208, TITLE 8. . . . Page 1 2 3 3 4 5 6 6 7 7 9 11 ***** _______ Appendices__________ ______ __ TABLES I THROUGH VII ATTACHMENT 1 - Statements on Availability of Substitutes ITEM 1 - Excerpt from Response by the Johns-Manville Company to EPA proposal on spraying (42 CFR No. 41). ITEM 2 - Excerpt from response from the Texas Refinery Corporation to EPA proposal on spraying (42 CFR No. 41). ITEM 3 - Excerpt from EPA rulemaking on spraying (43 CFR No. 18). ITEM 4 - Statement by the Flintkote Company. ITEM 5 - Statement by Chevron Research Company. A ATTACHMENT II - California Department of Health Report on Sandblasting of a Maintenance Coating Containing Asbestos <7 UCC 013927 A. BACKGROUND In 1974 a bill introduced by Senator Marks was enacted which prohibited, after duly 1,1976, the "spraying of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair." This bill was prompted by the spraying of asbestos building insulation materials in the San Francisco Bay area. For this type of application, dry asbestos mixed with other mineral ingre dients was delivered to the construction site in bags. It was then applied to the structure in two ways: 1. Sprayed in the dry form with a simultaneous spray of water so that it was deposited as a wet mat on the surface. 2. Premixed with water and sprayed as a thick slurry. By either method, the handling of the dry asbestos-containing materials produced clouds of airborne dust in the immediate vicinity of the mixing operation and in the general area of the building being insulated. After the insulation material dried, it became friable, i.e., could be reduced to a powder by hand pressure. It is highly possible that substantial concen trations of airborne fiber would be released during maintenance, renovation or demolition operations of buildings and structures insulated in this manner. No one objected to the banning of this particular use of asbestos. Exposures were difficult to control, could be high, and under certain conditions, could occur during the service life of the product. The Federal Environ mental Protection Agency promulgated a similar ban on the spraying of friable asbestos insulation materials in April of 1973. Manufacture of such products had generally ceased prior to the Federal action. The Marks bill was so broadly drawn that it banned not only this inappropriate use of asbestos but also a number of other important construction products wherein the asbestos fiber is wetted and encapsulated in a permanent binder or is present only in very small amounts. Fiber released during application and subsequent use of these latter types of products is non-existent or extremely small. It is worth noting that the Marks legislation contained one exception, cold process cutback asphalt roofing products, which is a typical example of the kind of products covered by this presentation. As more information showing very low worker exposure became available in 1975 and 1976 attempts were made in the legislature to modify the Marks bill to permit the continued use of these important products containing bound and encapsulated asbestos. In 1976 a bill introduced by Senator Presley was passed which provided a two-year exemption (until July 1978} from the ban for certain of these products and for Portland cement plaster that contained less than one-half of one percent asbestos. The two-year limit was a compromise to allow the manufacturers more time to search for substi tute materials and for the Department of Health and others to obtain more definitive exposure data. The manufacturers of the affected products agreed at that time to provide suitable sites for DOH testing of fiber,release. A u8 4 4S UCC 013928 -2- A. BACKGROUND (Cont'd.) The subject of exemptions was again addressed in the legislature in late 1977 and early 1978. It soon became evident that the legislature was a difficult place for objective consideration of this complex technical issue. The Standards Board, who has technical resources and capabilities, was clearly a more appropriate agency to act on the matter. A compromise bill, SB-1591, co-authored by Senators Marks, Gregorio, and Presley, was passed which transfers responsibility for the matter to the Standards Board. SB-1591 places certain specific limitations, beyond those already contained in Section 5208, Title 8, on regulations relating to exempted products, as follows: . 1. The maximum allowable 8-hour time-weighted average exposure cannot exceed one-half of the present level of 2 fibers/cc longer than 5 micrometers, i.e., 1 fiber/cc >5p. 2. The fiber concentration restriction applies not only to the spray application of the product but also throughout its use and disposal. B. SCOPE OF THIS PRESENTATION SB-1591 relates to three different types of products: 1. Portland cement plaster containing less than one-half of one percent asbestos. 2. A variety of products where the asbestos is wetted and encapsulated in a permanent binder. These fall into two related groups: a. Interior and exterior coatings and laminating resins containing encapsulated asbestos fibers bound within the finished product from manufacture through application. b. Cold-process cutback and emulsified asphalt coatings. 3. Any substance which contains less than one-quarter of one percent asbestos which occurs solely as a result of naturally occurring impurities in the substance or its components. This presentation covers the encapsulated products in Item 2 above and will address questions 3, 4, and 5 in the Notice of Public Hearing dated August 8, 1978, as follows: UCC 013929 A08449 B. SCOPE OF THIS PRESENTATION (Cont'd) "3. If exemptions for any substances containing asbestos are granted by the Board, at what level should the time-weighted average concentrations limits or ceiling concentration limits be set? (Section 25910(b)(3);(c)(3}; and (d)(3).) 4. Upon what basis, if any, should products containing "encapsulated asbestos fibers" be exempt? (Section 25910(c)(1).) 5. Upon what basis, if any, should "cold-process asphalt roof coatings" be exempt? (Section 25910(c)(1).)" The applications, characteristics, and quantities of the various products of interest are described and the status of the search for substitute materials is shown. Airborne fiber exposure data collected at 34 locations are presented to demonstrate that the fiber counts are consistently below both those allowed for other asbestos-containing products under DOSHA regulations and the more stringent limitations imposed by SB-1591. On this basis, suggested changes to Section 5208, Title 3, to permit continued use of these products are presented. C. PRODUCT USE INFORMATION a) Roof Coatings ( Many commercial and industrial buildings constructed today are topped with "built-up" asphaltic roofing. In the installation of these roofs a layer of hot tar or asphalt is mopped or brushed onto the roof and covered with a layer of building felt. The process is repeated until the required number of layers has been installed. The roof joints and flashings are sealed with thicker asphaltic-based "plastic cement" applied with a trowel. In this type of installation the asphaltic compound generally does not contain asbestos or other mineral additives. The building felt may or may not include asbestos, and the trowelable sealer will generally have asbestos as an important viscosity control additive. For proper application, the asphalt is heated to 450-500F and is then hauled to the roof in drums or pails. It is difficult and dangerous to handle and is too hazardous to spray. The heating is done in kettles which may emit smoke and fumes that are potentially harmful to the envi ronment. Environmentally acceptable kettles are expensive and difficult for the smaller contractors to obtain. As an alternative to heating, cold asphalt can be diluted or "cutback" with a solvent or emulsified with water to reduce the viscosity so that the material can be spread on the roof. Such products are termed "cutback" or emulsified asphalt coatings. These products require no heating and can be applied by spraying or rolling. They were used in the past mainly for maintenance and repair of existing roofs; but, with increased labor costs and improvements in spray equi/^^,/tjiT&* UCC 013930 -4- C. PRODUCT USE INFORMATION (Cont'd.) a) Roof Coatings (Cont'd.) are now finding much wider use in new construction. Spraying is about ten times as fast as hand application, gives a more uniform coating and permits pumping of material to the roof instead of using drums or pails of hot asphalt. The amounts of the various roofing products sold in California in 1975 are listed in the table below. Of the 8,042,000 gallons used, it is estimated that, most of the black emulsions and cutbacks and about onehalf of the aluminized products contain asbestos, that is, about 4,300,000 gallons. Product value for this portion of the total is about $5,000,000 per year. Most of these materials are sprayed. Company Black Cutbacks A 214 B 412 C 160 D 150 E 67 Totals 1003 1975 SALES DATA(^ (in thousands of gallons) B1 ack Emulsions Primers Aluminum Piarrented Neg. 143 165 138 19 291 1800 35 140 0 40 75 941 ___ g 37 2879 237 708 Plastic Cements 33 737 290 250 127 1437 Other 1328 420 30 ___ g 1778 "(1) Consideration of Model Organic Solvent Rule Applicable to Architectural Coatings, State of California Air Resources Board, June 1977. Table VII-7, p-61. " The asbestos content of these products varies from 4-13% by weight. The base asphalt is in the form of an emulsion containing about 45% water or cutback which contains about 40% organic solvent. The water or solvent evaporate during cure to leave an asbestos content ranging from about 6-20% by weight in the cured coating. b) High-Performance and Specialty Industrial and Trade Coatings and Resins This broad group includes a wide variety of high-performance and/or corrosion resistant coatings generally applied to metal, concrete, or wood. High-build vinyl, epoxy, and epoxy-coal tar based coatings, zinc-rich primers and block and foundation coatings are typical of this group. Some typical formulations of high-performance industrial coatings are shown in Table I in the Appendix. These products are used in shipyards, power plants, oil refinery and building construction and maintenance, oil and gas storage tanks, barges, off-shore drilling rigs, and in general, on almost any aB4-5 i UCC 013931 -5- C. PRODUCT USE INFORMATION (Cont'd.) b) High-Performance and Specialty Industrial and Trade Coatings and Resins (Cont'd structure that is subject to corrosion or requires water resistance. In addition to the main types cf sprayed materials just described, there are a variety of polyester resins used to provide such things as corrosion resistant linings for chemical process tanks and in the manufacture of fiberglass boats, tub-and-shower stalls, and similar glass-reinforced products. Approximately $4,000,000 per year of asbestos-containing coatings of the type described are used in California each year. These coatings are generally applied by spraying due to the nature of the surfaces coated and the high labor costs for other application methods. Typical application rates are shown below and it is evident that the use of a brush results in a very substantial addition to the cost. Conventional Air-Supported Spraying - Airless Spraying - ? 1000 ft. /hr. 2000 ft.^/hr. Brush - 200 ft.^/hr. The products described in this section contain 0.5-3% asbestos by weight as sprayed and up to 5% by weight in the cured coating. D. AVAILABILITY OF SUBSTITUTE MATERIALS In developing regulations for the control of potentially harmful materials, an important consideration is the availability of substitutes. However, substitutes must be proven harmless (or clearly less harmful) and economically competitive, and must perform the functions of the original material and impart the desired properties to the final product. It is equally important that any substitute whose use is, in effect, mandated by regulation be generally available and be thoroughly demonstrated as practical in actual commercial operations. Asbestos consists of fine, hair-like fibers which, when dispersed in a liquid, form a loosely-connected network which could be described as a three-dimensional spiderweb. This network initially thickens the liquid; but, when the liquid is pumped through a spray nozzle, the network comes apart and the liquid is thin enough to pass easily through the nozzle. When the liquid spray reaches a solid surface, the fiber network immediately reforms and thickens the liquid to prevent sag or run-off. The asbestos fiber network in the sprayed product also provides a bridging effect over irregularities in the base surface, adds strength and toughness to the cured coating, and imparts a certain amount of fire resistance in some compounds. Thereareno generally recognized and acceptable substitutes for asbestos fibers which so effectively perform the functions described above. UCC 013932 -6- D. AVAILABILITY OF SUBSTITUTE MATERIALS (Cont'd.) Since many fillers are less expensive than asbestos, the search for alternatives has been ongoing for many years, not necessarily prompted by the asbestos/health question or regulatory activity. However, these factors have clearly intensified the evaluation of substitutes in recent years. Some organic thickeners have been evaluated as asbestos replacements, but most work has been concentrated on other naturally-occurring fiber-like materials and man-made fibrous products such as fiberglass and mineral wool. Efforts to replace asbestos have been largely unsuccessful because the substitutes usually cause a substantial loss of functional properties and/or an increase in product or installation cost. Few manufacturers of the products under consideration desire to use asbestos in the present climate of concern over the asbestos/health relationship if a suitable substitute is available. An asbestos-free product with even approximately equivalent cost/performance would have a considerable advantage in the marketplace. The lack of such products is prime evidence that asbestos is an important and necessary raw material. Five specific statements on substitutes are provided in Attachment I. Three of these, including the conclusions of the Federal EPA, relate to a recent rulemaking on spraying of asbestos-containing materials and were obtained from the official record of the EPA proceedings. Two were prepared specifically for this hearing. E. WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS Exposure to asbestos in the workplace is measured in terms of the con centration of asbestos fibers longer than five micrometers per cubic centimeter of air. To make the measurement, the fibers are collected on a filter and are counted with a microscope at 400 to 450X magnification. a) Sources of Exposure Data Data on worker exposure during spraying and renovation or demolition operations involving the products described herein are available from a variety of sources. These include: 1. Responses to a Federal Environmental Protection Agency proposal to modify spraying regulations (CFR-42, No. 41 Wednesday, March 2, 1977). 2. A paper presented to the Society of Plastics Engineers.^ 3. A cooperative Government-Industry study on sandblasting of a maintenance coating which was carried out by the California State Department of Health and is reported as Attachment II. 0) "Consumer Safety in Plastics Systems Containing Bound Asbestos Fibers," M. B. Rhodes, Union Carbide Corporation. Presented at the Society of Plastics Engineers, Inc., NATEC Meeting, Denver, Colorado, November 9, 1977. 4o UCC 013933 -7- E. unRKFR FXPOSURE TO AIRBORNE ASBESTOS FIBERS (Cont'd.) a) Rnurrps of Exposure Data (Cont'd.) AH of the data presented are results from personal samples collected in the worker's breathing zone and most were obtained under routine commercial operations. b) Presentation of Results. The airborne asbestos fiber counts for over 100 individual samples collected at 34 locations are listed in Tables II through VII and in Attachment II. These results are summarized in the table below and are shown graphically in Figure 1. For this summary, the data have been grouped by two main product types, Roofing Materials and Coatings and Resins. Each type is further subdivided by the operation being tested, i.e., spraying or tear-off or abrasion of the cured products. The range of fiber counts and arithmetic average are shown for each product type. The arithmetic average represents actual exposures during equipment operation and would be the maximum exposure if the operation was performed by the same worker for an entire eight-hour shift. However, spraying, as an example, is a very rapid operation covering 1000 to 2000 square feet per hour. A worker would normally perform this operation for only a few hours, or less, in a working day. Therefore, a worker's actual TWA exposure would be reduced by whatever fraction of the day the equipment is not in operation. For purposes of this presentation, it was considered appropriate to use the arithmetic average (which would be the hioher number) rather than calculate TWA's for the entire shift. c) Discussion of Results It is clearly evident from Figure 1 that none of the individual samples even remotely approach the allowable ceiling limit of 10 fibers/cc >5u. The highest value of 1.6 fiber/cc >511 occurred during the sandblasting test and the next highest value was only 0.6 fibers/cc >5u, a factor of nearly 20 below the established limit. Similarly, the arithmetic average values were well below the 2 and 1 fiber/cc >5y limits prescribed by DOSHA and SB-1591 respectively. The sandblasting study reported in Attachment IT is particularly important to the present rulemaking since it represents an extreme test of the extent of fiber release from non-resilient coatings.(I) The entire coating is removed and reduced to a powder by the highenergy action of the blasting. (1) Note: Sandblasting is not applicable to resilient materials such as roof coatings which must be removed by other means. 4 UCC 013934 04 -8- SUMHARY AIRBORNE ASBESTOS TIBER CONCENTRATIONS Spraying and abrasion of products CONTAINING NETTED AND SOUND ASBESTOS FIBERS ROOFING MATERIALS Spraying Cutback Asphalt Asphalt'EmutSion Ueiqht I Asbestos As Sprayed Atter Cure 5.8-7.7 9.7-12.8 Z.8 S.l Tearoff & Replacement Built-up Roofing 0) 2.8-7.7 5.1-12.8 Number of Locations Tested 3 2 8 13 Number of Samples Collected 5 3 <13 <2U Airborne Asbestos Concentration (Fibers/cc >5u) Ranee Arithmetic Averanp 0.003-0.03 0.04 0.01-0.3 0.1 0.0-0.6 0.0-0.6 0.1 Cat a Reference Tables 11 i III Table 11 Table IY COATINGS AND RESINS Spraying Epoxy and Epoxy-Coal Tar Coatings 1-1.5 Chemical Resistant Polyester Coatings 0.7-1.4 Alkyd Solvent Coatings 6 Vinyl and Acrylic Latex Coatings 0.6-3.7 Polyester Laminating Resins 0.5 0.5-6.0 1.3-1.3 0.7-1.4 10 1.1-6.7 o.s 0.5-10 3 2 1 3 3 12 5 0.0-0.2 0.1 Table Y 5 0.0-0.4 0.3 Table v 2 0.0-0.05 0.03 Table V. 8 0.0-0.2 0.04 Table V 7 0.0-0.6 0.2 Table YI 27 0.0-0.6 0.1S(^ Abrasion Polyester Laminating Resins - Grinding Vinyl Utex Coating - Sanding Epoxy Maintenance Coatino - Sandblasting 0.5-3.0 0.6 0.6-3.0- 0.5-3.0 1.1 2.1 1.1-3.0 5 1 1 7 12 0.0-0.4 0.2 Table VII 4 0.0-0.3 0.1 Table YU 0.3-0.4 ,,, Attachment II 39 <0.1-1.6 (0.1-0.I)13' 55 0.0-1.6 (1) Results Include both the tear-off of old roofing end replacement with the asphaltic materials applied by spraying techniques. (Z) Overall average of 27 samples. (3) Eight-hour time-weighted averages. UCC 013935 4 -9- E. WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS (Cont'd.) c) Discussion of Results (Cont'd.) The subject of this test was a 40 foot diameter by 25 foot high metal tank that was spray painted in 1973 with an epoxy-based primer containing 2.]% by weight asbestos. The test was carried out in January 1978 so the coating was thoroughly cured. Two professional sandblast operators removed all of the paint on the vertical surfaces, one blasting for nearly six hours and the other for about two hours. They were assisted by a hose tender who kept the blasting equipment filled with sand and helped in the movement of the hoses, in accordance with California regulations, the two blasting operators wore respirators with an external air supply in addition to full protective hoods. Therefore, the data do not represent their actual asbestos exposure but only what it would have been without the required protective equipment. Even under these extreme conditions the maximum concentration found at any time was only 1.6 fibers/cc >5vi. The arithmetic average concentrations were only 0.3 to 0.4 fibers/cc >5u and eight-hour time-weighted averages, 'which are more directly related to statutory requirements, were even lower at 0.1 to 0.3 fiber/cc. As might be expected, the values obtained in the other sanding and grinding operations, where the rate of energy input was lower, gave consider ably lower peak and average values. (0.4 ceiling, 0.1-0.2 arithmetic average.) The arithmetic average dust counts show a generally random variation between a virtually undetectable level and 0.4 fibers/cc >5y. There does not appear to be any trend with the amount of asbestos in the product, the type of product, of the type of operation. The asbestos content of the product does not appear to be critical as long as the asbestos is sufficiently wetted and is encapsulated. F. BASIS FOR CONTINUED USE OF PRODUCTS As noted earlier, the Standards Board has specifically requested comments on what basis should be used for product exemption and, if exempted, appropriate ceiling and time-weighted average exposure limits. The air sampling data for a wide variety of products and operations show that these products consistently result in exposures that are both well below those allowed for non-sprayed asbestos-containing products by the present DOSHA Asbestos Regulations and also well below the wore stringent requirements set by SB-1591. These data demonstrate that special regulations for these products are not needed. Extensive and generally unsuccessful attempts have been made to find substitutes for asbestos. Economic considerations are substantial in that about $9,000,000 per year of such products are manufactured and used in California. UCC 013936 SUMMARY AIRBORNE ASBESTOS FIBER COuCFfl T RAT IONS - SPRAYING AND REMOVAL OF PRODUCTS CONTAINING WETTED AND BOUND ASBESTOS FIBERS -- HOOFING MATERIALS---- - - SPRAY ING-j |" REMOVAL*" COATINGS AHO RESINS SPRAYING ARRAS ION I Asbestos by Wt. As Sprayed S.8 - 7.7 3 After Cure 9.7 - 12.8 5 01.7--11..54 0.7-1.4 0.7-1.4 6 0.6-3.7 10 1.1-6.7 0.5 0.5 0.5-3 0.5-3 0.6 1.1 2.1 (1.) Arithmetic averaqe of all sanoles collected for each product group. Since these operations are generally intern ttant. the correspondic.q 8-hour time-weighted averages would be lower. 0.5-7.7 0.5-12.8 FIGURE 1 UCC 013937 -n- F. BASIS FOR CONTINUED USE OF PRODUCTS (Cont'd.) In answer to questions 3, 4, and 5 posed by the Standards Board, exemptions should be continued for the types of products discussed herein because: 1. They perform a valid and useful service. 2. They can be used at exposures well within those specified by the legislature. 3. No suitable substitutes are generally available. 4. Substantial economic considerations are involved. G. SUGGESTED CHANGES IN SECTION 5208, TITLE 3 A suggested format to incorporate the legislation contained in SB-1591 into the present asbestos regulations in Title 8 is presented in this section. This format is compatible with a similar treatment of the other two product categories under consideration in the manner indicated. Specific recommendations are confined to the product types covered in this presentation. A new subparagraph (1) is added to Section 5208 as follows: (1) Spraying of Asbestos-Containing Materials. (1) Except as provided in subdivisions (2), (3) and (4) of this subparagraph, no person shall cause or permit the spraying of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair. (2) Insert v/ording to provide a specific exemption for Portland cement plaster (if the Board decides that such an exemption is appropriate.) (3) Exterior and interior coatings and laminating resins containing encapsulated asbestos fibers bound within the finished product from manufacture through application, and asphalt roof coatings, shall be exempt from the prohibitions of subdivision (1) of this paragraph. (4) Insert wording to provide a specific exemption for substances containing asbestos which occurs solely as a result of naturally occurring impurities in the substance or its components(if the Board decides that such an exemption is pparopriate.) A UCC 013938 -12- G. SUGGESTED CHANGES IN SECTION 5208, TITLE 8 (5) During any use, spraying, application, handling, storage, repair, disposal, processing, or transportation of such products, the person who causes or permits such acts pursuant to an exemption granted in sub divisions 2, 3 or 4 of this paragraph, shall comply with the provisions of Section 5208, Title 8, California Administrative Code as it exists on the effective date of the amendments to this paragraph enacted by the Statues of 1978 or may, thereafter be amended. The time-weighted average concentration limits for employee exposure to airborne asbestos fibers arising from any use, spraying, application, handling, storage, repair, disposal processing, or transportation pursuant to exemptions granted under subsidivisons 2, 3, or 4 of this paragraph shall be no higher than the level contained in Subparagraph (A), paragraph (1), subdivision (g) of Section 5208, Title 3, California Administrative Code, as it exists on the effective date of the amendments to this section enacted by the Statutes of 1978 or as such regulations may, thereafter, be amended.- ( UCC 013939 4 08 4 -- ^ od TABULAR DATA Tables I - VII UCC 013940 A846C s UCC 013941 TABLE II AIRBORNE ASBESTOS FIBER CONCENTRATIONS., SPRAYING OF FIBRATED ROOF COATINGStl) Date 9/25/74 10/9/74 Binder Cutback Asphalt Cutback Asphalt Approximate Wt. % Asbestos As Sprayed After Cure 7.7 'v12.8 - Airborne Concentration (Fibers/cc >5u)______ (2) From Total Background Spraying 0.023 0.02 0.003 0.026 0.02 0.006 7.7 M2.8 o.n 0.038 0.072 . 0.065 0.038 0.027 12/10/74 Asphalt Emulsion 2.8 ^5.7 0.16 0.15 0.01 0.77 0.75 0.02 5/19/76 Asphalt Emulsion 2.8 ^5.1 0.80 0.50 0.3 (7) Data from a response by the Flintkote Company to "Changes in the National Emission Standards for Hazardous Air Pollutants" (40 CFR, Part 61) proposed by the PA (42 CFR No- 41, p. 12722, March 2, 1977., Conmercial conditions simulated. (2) Background before start of spraying test. A08462 UCC 013942 Binder Cutback Asphalt Cutback Asphalt TABLE III AIRBORNE ASBESTOS CONCENTRATIONS SPRAYING OF CUTBACK ASPHALTIC* Weight % Asbestos As Sprayed ^5.8 ^5.8 Cured 9:7 9.7 Sample Time (Hours) ' sJ" 7.2 Ai rborne Asbestos Concentrations (Fibers/cc 5 ) 0.09^ 0.15(2) (1) 260-265 gallons sprayed. (2) Sample possibly contaminated with background non-asbestos fibers from the roof. *Data from response by Texas Refinery Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants" {40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977. 4o`3463 UCC 013943 TABLE IV AIRBORNE ASBESTOS FIBER CONCENTRATIONS TEAR-OFF AND APPLICATION OF 8UILTUP ROOFING*** Date 3/14/74 4/10/74 5/21/74 7/25/74 11/20/74 12/16/75 8/16/76 8/16/76 Location Wisconsin Indiana Pennsylvania Indiana Colorado Colorado Indiana Indiana Operation New Application Tear-off Tear-off and Replace Tear-off and Replace New Application New Application Tear-off and Replace New Application 00 Airborne Asbestos Concentration (Fibers/cc >5u) 0.2 - 0.6 0.0 - 0.2 0.1 - 0.2 <0.1 0.0 0.0 1 1 oo (*) Data from response by the Johns-Manvilie Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants" (40 CFR, Part 61).proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) A084q^ UCC 013944 AIRBORNE ASBESTOS F tPER COHCF'ITRAT IONS SPRAYING OF HIGH-PEkFORKANCE INDUSTRIAL AND TRADE COATINGS 4Rl i e o u +> i. o jQO IAU *CJN*/ --W IA U41 vU. < *: c .o o ou. fV9-. a&> <= (OKS V7 >\ O TJ<3U- <Jj N- q. 3 x: oo o >s O "O n o> U T7 Cl >> C vl L. O* *Q CL L- A E LO o* *3 Vo <TS _ **L. 4f S *- Qd). T5 OU --3 n Wt- a >> *o0 a. >, s41- ~401 Li o >*- -*-* un n e -- -->1 JX o 1_ Ea <-> ^ OOO -- *IQ->*-D* *c" <Uv LCJ O =C a O Aj O - E E L vt L +Oj *--a Cm>L 4>Q U OEc 4 Go *w0 :( < *r- n> 11 I O U r-- C fUlj **J> ' r- vi c S O --*A */ -C 41 41 UL L EA Uo <CV o V *CL <0 EC O Mi WY U o4) 3Q. VA U U rcH--nJ u ^ qj o ^ yo tu V t4-J -O *3C-x^C>3 u_ SC> kos k ti UCC 013945 v ia w UC VO L <r* vi U (U v r-- 4; CL & Oo oo o ao o o o >> u > a> oc a -o (X 3 <0O / a. c o " Ol rtJ w* 2 i. U oo /0 U V. 0) o -- CL X o 4 uOrt._120 ocUx ta>-> in ` o Ci ~ ? ctr! oU. < Cooel ;' or3--1 <', 3 S c+- o3 a to >D =t L. VOll > < o o tO to to 0 oo *o w>* u <1 F- X >> ?? o o IS; u <c) 41 oc a> co *o > Q. 0 leO O' V* o r^. i a4) x tO X cn Oi U coo *J0 L C .-- > UCC 013946 OO OO r- >t> o_ a2v L t Ol au 2o iq o *t> -- vv>> tv T! c 4 M<<0 OX *i-A co V cU V*-I vim L. c #w0 -o m x oi fC- uCi *a--> uo -C- W*F I--1 O VI CO o* vi a. c> gn-f o <w V) > >1 >> O V)^2 V vi uoo *44r-/0>-1 t0Vn*O0L. r- _C ra. -*- o e -m CJ *v- o r>J fSJ rs. dd X 4 AJ 3 LV, 3 U OL O lA lA o u 4) <r>r O fO *o 4A1 2 X tn <o 0 E O c a in T5 co o oc 15 o oon u (M m 06 Oc t/a> - A Qe) vot'aJj o OU 41- Vi. Vu AL. J4D1 CV t- << CD*- t/ a> uo u*.- #-- 4# - AT O >> 1 SQO-. XASIC^sV- (A *" c *- 4iO- */- "O - qj a? dt4-)j DlIaOo., <iA/t oa-C^jCV ro*i O 1 x> fOJ t- 4C1L 1/1 t- a. w 41 CTO ^ CL C JUZ CT o *~ oo tt> cn Q. C O o -- z: 4ac>) AIRDOnNE ASnESTOS FIBER COUNTS - SPRAYING OF LAMINATING RESIN a< < toos-. <o/t Vu) CL U o oOE cc?ii t! C<aoL.'Oiaa; (A O i/i vo *(-> 4-> i(A X VX A > XN cO3 Drr--*\ c CO * u 4- 41 C5->-B4> IA O i>/Is*0 cc -.3! S- J <0 HOC-) . UCC 013947 A084 6.7 TA61E VII AiWOJNE ASBESTOS FIDER COUNTSGRINDING AND NAT;M1.G 0? .'OLHESTER 3- Sr.-DASFO SYSTEMS ClViTAl\;:.u ASBESTOS Sample Designation Date Type Asbestos Appro*.. It. ; As Sfter Sprayed Cure Operation l. ihc5*--sct a:s ',?l (?0*. vester] 1929-82-3 Fabrication of reinforces fiberglass pipe. 1929-82-4 - 1929-82-S 2/27/73 RG-144 20 2-3 Operator Dulls pipe along line. Saws off end with circular saw. ft 2-3 2-3 Same operation as 1929-82-3. " n 2-3 2-3 Operator reaving end of pipe with scarfing mac-iine. M3 1-6 * 3/13/74 RG-244 1.4 1.4 1.4 Operator shaninn end of pipe with bell A spigot machine. 1.4 Operator cutt'ng off pipe end and lignt grinding on exterior surface. Sample Time (Min.) 19 49 45 16 17 1-26 c-8 Vj9 1929-84-4 1929-84-5 Fabrication of FftP tanks and pioe. ' Production of artificial Pricks. 8/13/74 RG-244 * * l.S 1.5 3.5 3/8/73 RG-244 2.0 2.0 1.5 Operator grinding inside of W \ .6. x 26 ` tank. 1.5 Continuation of same opera tion as i-26. 1.5 Operator Grinding edges of miscellaneous small parts. 2.0 Operator cutting with sabre saw. 2.0 Operator trimming with sabre saw. 16 5 25 44 39 "-20 lt-25 Production of fiber glass boats. 11/28/74 RG-244 0.5 0.5 0.5 Ooerator grinding inside of boat hul1. 0.5 Operator grinding. 11 4 t. ]HTL LATEX RESI,\t2' 2-33 R-43 Sanding of vinyl latex paint. 3/8/77 T-135 0.6 ft 0.6 1.1 Operator bandsamUng overnead panel. 1.1 12 11 2-35 - 0.6 1.1 Operator handsanding wall panel 16 J-4 a 0.6 1.1 16 Possible Airaorng Ashe-s '.as Fiber Concentrarcn (F:bcrs/cc '5.) 0.1 0.1 0.04 0.3 0.2 0.4 0.3 0.3 0.1 0.2 0.0 0.0 0.3 0.06 o.r 0.0 0) ConAu-r 5of>:tjf in Plastics Syatemi Containing Scmd A.bestos Fibera,* paper presented at the Society of Plastics Engfneen, Inc. NAT EC toetihg. Denver, Colorado, November 0-10, >977 by Harrison 8. Rhodes, {1) Cornwrcitl conditions simulated. UCC 013948 ATTACHMENT I Statements on the Availability of Substitutes for Asbestos UCC 013949 *084 69 ITEM I Excerpts from response by the Johns-Manvilie Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977): "Asbestos is used in asphalt coatings for three reasons. First, to add body or enhance the rheology of the coating, especially the thixotropic characteristics. Other fibers, such as fibrous glass, do not have sufficient bulk to serve as an adequate substitute. Second, since many of the applications for asphalt coatings involve outdoor exposure, the fibrous nature of asbestos provides superior weather resistant characteristics. Third, the low cost of asbestos in relation to the value added is superior to other mineral fillers, and essential in the manufacture of asphalt coatings, ( which are generally low cost products. A J-M Technical Bulletin describing the use of asbestos fiber in asphalt coatings has been provided as Attachment I. " UCC 013950 ITEM I Cont'd Vxi j - y V . KS v' M !, V. V ') Asbestos FiberC ^jlsa'VSOtJg-*Vy Chrysolite schnlc&i Bofeiia Asphalt Coatings Asphalt coatings represent a line of products which have a variety ot end uses in the industrial, automotive and con struction industries. They are produced tor such varied uses as protective coatings tor metals and tanks, insulation for pipes and tanks, sound deadeners, sealants and undercoat ings for automobiles and root coatings, (lashing cements and tile cements in construction. One type is made from an asphalt cut back with kerosene or mineral spirits used as a solvent and the other with an asphalt emulsion in water. Purpose of Asbestos The primary purpose ot asbestos in coatings is to enhance the rheology of the system and especially the thixotropic characteristics. Since many ot the uses involve outdoor exposure the excellent weathering resistance imparted to the coating by asbestos is essentia) and its fibrous nature provides the desired viscosity characteristics The low cost of asbestos in relation to the value added is essential in these low cost products. Formulations Because ot the variety ot products and the number of pro ducers there are unlimited lormulaltons. The major compo nents are Cutback Products Cutback Asphalt Asbestos Limestone or Slate Fluor Qispersant --30-80% --10-15% --15-30% -- 1% Emulsion Products Emulsion Asphalt --55-80% Asbestos --10-15% Limestone -- 5-15% Dispersant -- 1% Aluminum paste is added to give a reflective coating; granu lated cork for insulation Manufacturing Process The manufacturing process consists of mixing and packag ing and ihe sophistication will depend on the size of the operation. Mixing is accomplished in horizontal mixers ot the helical type or vertical or horizontal mixers with paddle blades. Most of the time the dry ingredients are added to the cutback asphalt and mixing is continued until a homoge neous mix is obtained In some cases the order of mixing may be reversed or only some ot the dry ingredients mixed initially. When mixing ts complete the unit is emptied into packages which may vary from one and live gallon pails to barrels. Some products, especially those used in airless spray oper ations, require straining before packaging. Recommended Fiber Grades 7M05 7R05 7T05 7MF5 7RF02 7TF1 7TF02 CAUTION Contains Asbestos Fibers -- Avoid Creating Dust -- Breathing Asbestos Dust May Cause Serious Bodily Harm Tlv* phys*ca* (<*' cte%C3l} proc^rr-c* qI Johns-M.irwcHo Chrysoriic Asot-Mos f <b-r /ep*e**Al typical Average vetoes ootjiri*?U ,n accordance *ijh ;i.cepie<J t,t mitujiii twxi G(<s %ubtcI <o normal manulaciimng vanjj.ijru They arc tut.DSiutJ os j fecnrucdi \ervico .nij 1o4m esunbl jiencfot rtmo acthioannge without notice. Check Um* John* Mjnviiie otvtnct o'licc to iv.wte ATTACHMENT I |n^f *0 e UCC 013951 Sit J AtO4ta f'lbec S*f* * P O Do* })0I Denver. Colo 602tl * {303)770-1000 John* ManvtM* Co .ltd Av>*tot ftbir 0i****un P O 0o* 1500 * A5b**io*. Quebec. Canada Jll 3N2 &73 S433 ITEM 2 Excerpts from the response by Texas Refinery Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants11 (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977): "These coatings are used in spray applications because of convenience, safety and the ability to get a uniform coating. Spray application of these coatings is conven ient since the containers of coatings are left on ground level and pumped through hoses to the spray nozzle on the roof. It takes fewer persons to spray a roof than to apply it by hand in the same time period, and containers do not have to be lifted to the roof, emptied by hand and the empty containers lowered from the roof along with other equipment necessary to apply by hand. Spray applications are safer due to the fact, as mentioned previously, that the only appratus needed to be raised to the roof is the spray hose and nozzle while the heavy containers of coatings are left on ground level; not as many workers are needed up on the roof and therefore are not taking risks of falling; and less waste is generated since no rags or brushes are used. Also,most roofs develop low spots during aging which will result in a heavier deposit of coating in the low spots than in the high spots when the coatings are applied by hand. These heavier deposits will cause problems with the efficiency of the roof which will result in workers having to return to the roof for patching work. This in turn results in add ed expense and re-exposure of workers to safety hazards. A spray application usually results in a uniform layer of coating over the roof regardless of any indentions or low spots on that roof. Our company has investigated several types of asbestos substitutes for use in these coatings and found none to be satisfactory. Several types of clay thickeners, includ ing Attapulgite, ground cork, styrofoam, ground rubber, vermiculite and Feldspar have been investigated and found to lack the characteristics necessary to impart strength to the coating .Polyethylene fiberous powders were tried and found to dissolve in the solvent system and/or not to impart fire resistance or strength necessary to the coat ing. Hemp and other organic fibers were investigated and found not to impart bio logical resistance necessary to prevent attack of the coating or fire resistance. A ceramic fiber was tested and found to give strength, fire resistance and biological resistance to the coatings. However, a problem with settling of the coatings over a period of time was noted; the ceramic fiber is not widely available and is very ex pensive. The ceramic fiber we have tested from Babcock and Wilcox is selling for $0.80 per pound in carloads while asbestos is obtained in carloads at $0.0955 per pound. Also, since this branched, soft, fairly long ceramic fiber has only been found available from the one supplier, it is doubtful whether or not supply would be adequate for complete substitution - industry wide. Substituting the ceramic fiber for up to 10.5% asbestos used in these coatings, cost increase to these products would be substantial. If the coating materials which we produce have to be deleted from the line due to no acceptable asbestos replacement, figures- from fiscal year 197 6 show that 5 >588 million dollars in revenue will be lost annually by our company." UCC 013952 A'08472 ITEM 3 Excerpts from "Amendments to Asbestos Standard" (40 CFR, Part 61) promulgated by the EPA (43 CFR, No. 118, p. 26372, 26373, June 19, 1978) "Several commenters, however, requested that EPA exempt from the spraying restrictions certain bituminous- and resinousbased asbestos-containing coatings. These coatings are typically used as roofing compounds, waterproofing of insulation exposed to the weather, automobile undercoatings, and industrial maintenance coatings. Based on information supplied by the commenters, there are no acceptable substitutes available for these uses of asbestos. Among the most likely substitutes which have been investigated are glass, cotton, wood cellulose, mineral wool, hemp, and other types of inorganic and organic fibers; gelling and thickening agents; clay thickeners, including attapulgite; ground cork; styro foam; ground rubber; vermiculite; feldspar; polyeth ylene fibrous powders; and ceramic fibers. Generally, these substitutes have been found to be unacceptable because of unsatisfactory durability; insufficient bulk; unsatisfactory qualities related to fibrous reinforcing, homogeneity, and adhesiveness; agglomeration during spray ing; and settlement in the container over time. Further more, if asbestos fibers are released during application of the coatings, during their service life, or during demolition or renovation, the fibers will not remain airborne because they are encapsulated by droplets of the binder and are too heavy to remain suspended. Because there do not appear to be acceptable substitutes available and any beneficial environmental impact resulting from the prohibition of this use of asbestos would be negli gible, the spraying of materials in which the asbestos fibers are encapsulated by a bituminous or resinous binder and which are not friable after drying is exempt from the provisions of 61.22 (e) of the promulgated amendments." UCC 013953 408473 FUHTXorf TO Mr. Jim Hay INTER-OFFICE CORRESPONDENCE ITEM 4 DATE March 8, 1978 John Tamanen subject C-13-C4 WITH & WITHOUT ASBESTOS Asbestos is used in asphalt emulsions to provide reinforcement and aid in fire retardancy. Asbestos has high water or oil absorption, does not melt and will not burn or contribute to a fire. Organic fibers such as cellulose, polyethy lene, nylon or polyester as well as fiber glass or mineral wool, can be used to make fibrous asphalt emulsion products. They can be used in combinations or alone, but none have the same characteristics as asbestos. Organic and some mineral fibers will melt or burn at elevated temperatures, generally have a low water or oil absorbancy and can contribute as fuel to a fire. We have made- a few samples of C-13-C4 using blends of fiber glass and organic fibers. They do show some promise as far as manufacturing procedures and workability are involved. Further work is needed to determine storage stability, weathering characteristics and fire retardancy. JT:rb cc: Mr. W. Bradley FOAM 602 M UCC 013954 Chevron L^'J Chevron Research Company A Standard Oil Company of California Subsidiary b76 Standard Avenue, Richmond, CA 94802 J, H. Macpherson Vice-President ITEM 5 September 19, 1978 Mr. Harrison B. Rhodes Union Carbide Corporation Metals Division P.O. 3ox 579 Niagara Falls, New York 14302 Dear Mr. Rhodes: We understand that you plan to testify at the November 8, 1978, public hearing of the Occupational Safety and Health Standards Board relating to asbestos-containing products. In response to your request for information on substitutes for asbestos, we have the following comments: For several years now we have been actively searching for an asbestos replacement in our asphalt-based coatings. We have evaluated a variety of materials, but so far have ( found none that has the same cost/performance effectiveness as asbestos in our products. Asbestos fibers serve tvro purposes in our coatings: 1. It gives the freshly applied coating a thixotropic consistency that allows the buildup of a thick film without sagging. 2. It reduces the alligatoring of the asphalt film. We have tried various pigments and gelling agents. Pigments, such as mica, talc, slate flour, and carbon black, by them selves do not provide the thixotropic characteristics desired Thickening agents do impart thixotropic structure to the liquid; but they do not give the same sag resistance and film build. Polyethylene and polypropylene fibers also have been evaluated. These are advertised as asbestos substitutes. However, some of them could not be mixed into the coatings because of inconroatibility. Others did not have the required 40647V UCC 013955 Mr. Harrison B. Rhodes -2- ITEM 5 Cont'd September 19, 1978 sag resistance. The storage stability of the coatings made with these materials was also a problem. Due to cost and application problems, asphalt-polymer combinations have been eliminated as practical coatings. We expect to continue the evaluation of various materials as asbestos substitutes. However, at present we have no practical substitute for asbestos in our coatings. Very truly yours. ( UCC 013956 Ao<?6 ATTACHMENT II California Department of Health Report on Sandblasting of a Maintenance Coating Containing Asbestos ( UCC 013957 aOQ4 7? Due to logistics problems the final version of this report was not received in time to be included. It will be submitted directly to the Executive Officer of the Standards Board for attachment to this report ( UCC 013958 SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANCES IN THE HEALTH AMD SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Asbestos Fiber Exposure During The Destruction of Maintenance Coatings By Sandblasting Prepared for the Occupational Safety and Health Standards Board Sacramento, California November 15, 1978 Prepared By Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013959 SUMMARY AND CONCLUSIONS The air monitoring test during sandblasting at Corona, California that was reported in the October 30, 1978 DOSHA letter to the Standards Board was a cooperative study wherein Union Carbide Corporation and DOSHA collected simultaneous paired samples on the workers. A report of the Union Carbide results is provided herein. The UCC counts ranged from about the same to about one-half of those found by DOSHA. Considering the nature of the samples, both laboratories were in accord that the differences were due to the normal random errors in the sample collection and counting procedure and did not represent a significant difference between the laboratories. The critical problem with these samples was the presence of large amounts of mineral particulate that met the criteria for a countable fiber, but in all probability were only very rarely asbestos. An examination of three of the filters by scanning electron microscopy was carried out by Union Carbide. This study confirmed that free asbestos was rare and made up very roughly one countable fiber out of fourteen. This information led to a further cooperative, large-scale sandblasting test at Trona, California wherein the samples were collected by DOSHA and counted by the Federal OSHA Compliance Laboratory in Salt Lake City. The Federal laboratory has considerable experience with this type of difficult sample and uses a combination of sophisticated optical techniques and electron microsopy to aid in the identification of non-asbestos particulate. The results of this study showed a ceiling concentration of 1.6 fiber/cc >5y and 8-hour TWAs in the 0.1 to 0.4 fiber/cc >5u range. We believe that these levels, which may still be conservative (high), are more representative of asbestos fiber release from maintenance coatings during sandblasting than the data that either participating laboratory obtained at the earlier test at Corona. UCC 013960 4 os 4- fi 0 TABLE OF CONTENTS Secti on_________________________________________ A. BACKGROUND.................................................................................................. 1 B. RESULTS AND DISCUSSION 1. Fiber Counts by the Optical Phase - Contrast Method ... 1 2. Fiber Analysis byScanning Electron Microscopy...........................2 C. COMMERCIAL SANDBLASTING TEST....................................................................4 D. CONCLUSIONS ............................................................................................... 6 E. FIGURES 1-12................................................................................................7 F. ATTACHMENT I 1. DOSHA letter of October 30, 1978 to the Occupational Safety and Health Standards Board.................... 19 2. Appendix B of October 30, 1978 DOSHA Letter (Village Grove Park, Corona, California Test) .................... 21 3. Appendix C of October 30, 1978 DOSHA letter (Kerr-McGee Test, Trona, California)........................................25 G. ATTACHMENT II (Union Carbide Report of Cooperative Air Monitoring Test at Village Grove Park, Corona, California ................ 32 H. ATTACHMENT III (Protocol of Cooperative Air Monitoring Test at Kerr-McGee, Trona, California)................................................38 Page UCC 013961 A. BACKGROUND During the hearings on the 1976 Presley Bill, Assemblyman Fenton asked the Department of Health to collect additional exposure data during the use of the products for which temporary exemptions were eventually granted. A cooperative government-industry effort ensued. The data obtained were submitted to the Standards Board by Mr. James H. Heacock of DOSHA in a letter dated October 30, 1978 (Attachment I). Appendix A of this letter covered tests of Portland cement plaster. Appendices B and C related to sandblasting of maintenance coatings. This discussion is limited to maintenance coatings, the plaster applications will not be covered. The initial two sandblasting tests (Location 1 and Location 2, Appendix B in the DOSHA letter) involved the removal of an asbestos-containing coating from a plaster or a stucco.wall. When the results became available, they were higher than anticipated, i.e. 0.6-3 fibers per cc longer than 5v- The manu facturer of the paints then asked Union Carbide to participate in a third test jointly with the DOH. This was acceptable to the DOH and the Village Grove Park location in Corona was selected as the site. In this test the blasting operator, helper, and observer each wore two pumps and simultaneous samples were collected in the breathing zone with filter cassettes positioned on opposite shoulders. Paired background and area samples were also collected. A detailed report of the Union Carbide results is provided in Attachment II. For easy reference the corresponding DOSHA report has also been included in Attachment I as Appendix B. Only the key points of these reports will be summarized here. B. RESULTS AND DISCUSSION 1. Fiber Counts by the Optical Phase - Contrast Method The samples collected in the test at Village Grove Park, Corona were extremely difficult to count. They were heavily loaded with both fibrous and non-fibrous dust. Considerable particulates were present that met the dimensional criteria of a fiber, i.e. length greater than 5y, length to diameter ratio greater than three, but they were clearly not asbestos. Both counters were experienced and discussed the problem of evaluating filters of this type prior to counting. In an attempt to assess the impact of the asbestos fiber recognition problem. Union Carbide divided the fibers counted into two classes, "obvious chrysotile asbestos" and "possible asbestos fiber." When there was any doubt about a fiber's identity it was included in the count. The total of both classes would be the value ordinarily reported as asbestos. Particles which were obviously not asbestos were not counted. This included such things as unbroken fiberglass, mineral flakes with non-parallel sides, and particulate that appeared bright under phase contrast. It should be noted that the only known source of asbestos of any type was the 5% by weight chrysotile that was added by the manufacturer. (Note that the 2% asbestos figure reported by DOSHA in Appendix B is in error.) -1- UCC 013962 The Union Carbide results ranged from 0 to 0.8 fibers/cc >5u of "obvious chrysotile" and from 0 to 3.6 fiber/cc >5u for total asbestos. (See Attachment II.) These total values are compared with the DOSHA results for each paired sample collected on the opposite shoulder of the workers in Table 1. These values range from 0.1 to 7.1 fiber/cc >5y. Examination of Table I shows that the pretest controls and several of the samples collected on the observer and on the helper resulted in the detection of only several fibers in the hundred fields examined under the microscope. Blank filters, i.e. those which have never been exposed, will read from zero to several fibers per 100 fields, so these results really are not distinguishable from background. The remaining eight pairs ranged from about the same to a Cal/OSHA counting of about double that of UCC, 7.1 vs 3.2. Considering that these counts aj^ noif from the same filter but from filters that were collected on-opposlte shoulders, bth laboratories were in agreement that the differences were probably the result of random errors in the sampling and counting method and did not represent a significant difference between the laboratories. The time-weighted averages for the two operators for the time period where sandblasting was actively in progress and for the entire eight-hour day were calculated for each set of total asbestos count data and are listed below. The two workers' actual TV/A exposures for the particular day were all below 0.5 fiber/cc >5y. The highest value reported by either laboratory, 7.1 fiber/cc >5y is still below the ceiling limit of 10 fiber/cc >5y. Time-Weighted Average Exposures (Fibers/cc >5u) During Active Operations Cal/OSHA UCC 8-Hour Day Basis Cal/OSHA UCC Helper 1.1 0.6 0.2 0.1 Operator 4.1 2.2 T 0.2 0.2 2. Fiber Analysis by Scanning Electron Microscopy It was evident from the results that non-asbestos material was being included as asbestos in the counts reported. In order to check this further. Union Carbide examined three of the filters with a scanning electron micro scope. A small square from each of three filters was exposed to acetone vapor under conditions that had previously been determined to collapse the filter to a smooth surface but did not allow the particles to sink into the filter. Shrinkage in area was measured and found to be about 45%. The samples were then gold-coated and mounted for microscopic examination in the normal manner. A08483 -2- UCC 013963 TABLE I COMPARISON OF AIRBORNE ASBESTOS FIBER COUNTS DURING SANDBLASTING OF ASBESTOS CONTAINING MAINTENANCE COATING Describtion of Operation Saaote Oats Ti*t Total Wo. On Off Hin. Pretest Controls On fence, left side of ere* to be sand-blasted. --4 1/2 above jround. On fence. '-'100' from C-16. ^5` above ground. Personal senate on observer *25* from fence and roving S-1S 10:35 10:55 F-44 10:42 10:59 A-86 10:39 10:57 71 17 13 Observer (During Sand-Blasting) Personal sample on observer A-81 *20-30* from fence and moving parallel to fere*. U;12 11:75 1!:1S 11:27 Sam as A-81. J-89 17:26 17:52 Area sarple on fence. S' 6-3 above ground and -*40* down- tfind. (In 1iej of observer) 1:35 2:00 6 2 8 76 25 Helper (During 5ar-Blastfrt<t) Personal sample. Assisting with hoses. Operating sand feeding equipt-n:. G-48 11:10 11:18 8 11:74 11:26 2 1? Sam as G-48. 2-8 17:25 12:48 23 Sam as G-48. Sam as G-48. C-1S X-4 1:08 1:36 1:22 14 1:58 22 (lastinq Operator (Ourinq Sand-8 lasting) Personal sample. Operator handling sand-blasting acute, sundirg^Z* from fence. 0-71 11:10 11:18 a 11:24 11:26 2 Sam as 0-71. 1-14 12:25 12:36 It Sam as D-71. 6-34 12:38 12:4$ 8 Same as 0-71 except faside of hood. Sam as 0-71. 2-2 1:08 1:22 14 2-3 1:36 1:53 22 ucc 130 fields fjcc Cal/ttHA f/cc Fiber Cotnfcs Asbestos ucc sEm TfTcc) Kon-Asbestos Total Com&nts 2 0.1 0.3 00 0.1 2 0.1 0.2 1 0.1 0.1 1 0.03 0.2 29 0.7 1.9 0.3 15 1.0 1.4 78) 45) 1.1 2.2 3 0.2 0.5 2 0.06 0.2 32 2.2 1.6 431 58) 3.2 7.1 38 3.3 6.6 34 1.7 3.7 56 1.8 2.1 0.3 0.0 3 Asbestos 1.0 1.3 fibers In 2$ fields 1.5 1.8 3 asbestos fibers in 25 fields 4 asbestos 1.0 1.0 fiber in 75 fields ^054 04 -3- UCC 013964 Random fields were then selected and examined for particulate matter which met the "fiber" criteria, i.e. L >5u, L/D >3. Magnification was 1500X and the defined field area used was Q.0048mm2, This is similar to the optical counts where the field was 0.0062mm2. Whenever a fiber was found it was analyzed by Edex in the spot mode for chemical composition. Detailed results are listed in Table II and Figures 1 through 10, and are summarized below. Sample No. X-3 G-3 D-- 71 Total Fields Counted 75 25 25 125 Fibers Found^ Chrysotile Non-Asbestos 0 3 2(2} 34 n 19 5 64 Total 34 14 20 69 0) Length greater than 5y , length/diamer greater than 3. (2) Does not include a non- fibrous asbestos "clump". These data demonstrate that free asbestos fiber in the generated dust is both rare and a small fraction of the total fibrous particulates, in this case about one fiber in fourteen. The potential for erroneously high counts by the ordinary phase-contrast optical method is obvious. The number of fields examined for each filter and number of fibers found were too small for a reliable estimate of airborne concentration. As a point of interest, however, the fibers per cc values corresponding to the numbers of fibers found have been shown in Table 1 and positively identified chrysotile asbestos ranged from 0 to 0.4 fiber/cc >5y. These would be ceiling, not TWA values. C. COMMERCIAL SANDBLASTING TEST When these results became avilable, the problem was discussed with Mr. Heacock of the DOH and it was agreed that a carefully-planned, large-scale test using professional operators and equipment should be made. Samples would be collected by DOSHA and counted by the Federal OSHA Compliance Laboratory in Salt Lake City. This laboratory has had considerable experience with the type of highly contaminated samples expected and utilizes a combination of sophisti cated optical techniques and electron microsocpy to provide more reliable counts. Aoe < 36 -4- UCC 013965 TABLE II sample analysis by scanning ELECTROri MICROSCOPE Chemical Composition by EDEX Field Area 0.004&Twn^ ******* 9UU ft*. # L**fCft f<r -Jil0 0 a ft e a fst 1n1 1 Hu 1 S ft Vu 0 1? a 1 t 7.$ 7f4t t i 1ft ft II n 7 U I a a 14 n ft f1t 1 w n 17 24 a a 7a1 aa a a a aa a 41 41 47 a 47 a a a UimJ. <0. M .illii*!-' a lantw (M*a 1 ft u| . . i l I 1 I aw aaiuft i . l lxt 1 ..Ill........................... I*!***- .111--.-. . - X -- - --..1X1----.-111......................................... ..111----- - - I XI- - --- un.tetit*f (r**m 11 !> MO MMiMtUf Mtk (fata* 7 ft 3ft} lot* itaHksbntM Ail a4aia oMUita aw liiwra ft JokciUf a *m-4**m *TM. fHft*M. MW. nftf U<^J)Ji a ii 5i!a.*IiliSa.lis.Il _______ 14t*ti fifties . fA+bma 17*atai 14 l U)I 1 ------ 411 Hm <aa 1 ----- a K --xiillt a -X - 1 - " mo a mat - y fmTtoil K M'AUfttM II n ua a K < -xxx---- - a a a ft -I-ll--- - - y*lW*Wl a a 7 . -ill-- ... > Inna it ff7tt - - X X x............... ..................................... I . Hi a ftaa - - -ft-...-. a M I MMlM H ia haa iU Mg. l-i xtt /HM a. i Xft 4 1 4 7 ft 1 1ft 11 12 1ft M ftft. < liisa 1 1 ft 1 ft ft t 2 f1t 0ft Upfttft -UL. t I ft 1ft 7 7 ft Sl2lil2LStfitahll IdntlflcftHoft . ip4tititn -.-I...... laft-faMLtw --III*.--- - U-Aittiwi 1 - a Ulittw 1X X a AiKtm X1I --- ftqu a ahum 1ft 0 17 0 1| } 1ft 1 20 0 22 a ft 24 a fftt 2ft ft 77 ft 2ft ft n ft a9 31 1 a ft a0 a B f0t jx. 1 M B fftt a1 41 ft a0 4ft 1 44 i 4t 0 41 2 0 ft a ft 4ft 1 a C a i zi I 4 . - - 1- n - - - I- is . i i x is - - i 14 . - - * - 14 14 i x IS x ai lihnm a Mhnw a Htutn a iijftttf* taHUIttttt a>nat*i Ail a tiUitw iMfe toV-AlhltM aa-AsftatM y$jrr% It) tamivt Mima $ aa M MKAibtilK nu a. r a. _ nan t*i X 1 f74ftt 111u9ff1tt an111I1ISS4794 XT at* 2 ft 40fftt 1ff1tt ft ffff211ttttt 9 f1t W Iaof 1a11af744t fftt 1ISf4ff7ttt K W| fran- s*u a. ft-?? Uwnflena lii.-i- I-.--- ill...XX- X--III---- - a-Atbtim i*o a-AOfiut Mo a* ibm - XXI - II x tx Alt 1 - - 1 lAt**tn i/Kotwt S 1 5iTj - * - -t 4 v41 i . * I 1 X . * Hor-AiN^fot _ .|XXX.---- OHQMm *>6otOW *na 7*1 a i*ft4iouia (Mna). -M*i ~UwTtf-a M>*lb-*TtT7tit*i o*t*f** <ftwin). at c*M*t** m uw\ti . . - . I - - a4*.MitW X i- - (?hwio< iJT X XX -- *- -I {pat#* T)7Tfit T ) AQ<3-4*rr -- 1 I Mtoitn fan 1 MtnUi Clu UCC 013966 The protocol for this study is appended as Attachment III and the DOSHA Report (Appendix C of their October 30, 1978 submission to the Board) of the study is also given for reference. The DOSHA report covers the test very well although it should be noted that the Federal OSHA counter included any fiber of doubtful identity as asbestos so the results presented would be conservative (high). It is also appropriate to acknowlege that the test site was provided through the courtesy of Kerr-McGee Company at Trona, California. Figures 11 and 12 show photographs of the test which give a clear illustration of the nature and scope of the operation. CONCLUSIONS The fiber counts reported in Appendix B of the DOSHA letter of October 30, 1978 as well as the Union Carbide counts of the simultaneous counts include a great deal of material that is not asbestos. The subsequent large-scale test although possibly still conservative (high), is more representative of exposure during sandblasting. UCC 013967 Photo 1 - Sample X-3 @ 10.000X Photo 1A - Spot Mode of Particle Show Above UCC 013968 FIGURE 1 Photo 2 - Sample'X-3'1? 1500X Photo 2A - Spot Mode of Particle Circled Above 4 nu^4sg -8- h UCC 013969 FIGURE 2 Photo 3 - Sample. X-3 @ 1500X Photo 3A - Spot Mode of Particle Shown Above -9- UCC 013970 FIpURE 3 tI Photo 6 - Sample D-71 @ 1500X Photo 6A - Spot Mode of Particle Shown Above -10- A0H_9j______ UCC 013971 FIG4Uw RE 4 1 I Photo 5 - Sample D71 9 15001L Photo 5A - Spot Mode of Fiber in Above Photo UCC 013972 FIGURE 5 Photo 7 - Sample D-71 15.000X Photo 8 - Sample 0-71 9 1500X Photo 7A - Spot Mode on Particle Shown in Ph 7 and 8 -12- UCC 013973 FIGURE 6 Photo 10 - Sample D-71 (? 5000X Photo 10A - Spot Mode of Particle Shown Above UCC 013974 13- FIGURE 7 Sample 11A - Spot Mode of Particle Circled Above -14- UCC 013915 FIGURE 8 Photo 12 - Sample D-71 (? 20.000X i Photo 12A - Spot Mode of Fiber Particle Shown Above -15- UCC 013976 FIGURE 9 Photo 14 - Sample 6-3 @ 1500X V Photo 14A - Spot Mode of Particle Circled Above 4 Q? ! -16- UCC 013977 FIGURE 10 COMMERCIAL SANDBLASTING TEST KERR-MC GEE CORPORATION - TRONA, CALIFORNIA Ae498 Operators Sandblasting Bottom Portion of Tank ~17- UCC 013978 FIGURE 11 uunncrvuinL jnnuuLnjuiiu iuui KERR-MCISeTWORATION - TKTOrCALIFORNIA Operator on Manlift Sandblasting Top Portion of Tank DOSHA Representative Collecting Samples and Recording Data 1Q i UCC 013979 FIGURE 12 jTATf OF CALIFORNIA DEPARTMENT OF INDUSTRIAL RUATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 44> ? WEST TfMfLE 103 ANCEltS. CA 90026 Gor*rn*rIDMUND O. MOWN Jt . ADDAIft RtFtY TO: 449f WEST TCMPlt LOS AHCtLtt. CA 90024 October 30, 1978 REcIVD Occupational Safety and Health Standards Beard 1006 Fourth Street Sacramento, C\ 95G14 H0V 6 1978 * Gentlemen Subject: Public Hearing November 8, 197S Asbestos Products in 3uiidings` and Structures The Occupational Health Branch of the California Department of Health evaluated employee exposures to asbestos during the destruction of building materials in an industry-government cooperative consultation program. Results of those tests have bearing on all items of the hear ing and specific information on Items 1, 2 and S. Previously applied sprayed materials containing asbestos were removed by sanding or sandblasting, or the structure demolished. The employees doing the work were sampled and results analyzed in the same manner as any other compliance or consultation CSHA samples would be handled. (In one study, samples were analyzed by the Federal QSHA Laboratory in Salt Lake City in the hopes that advanced analysis might be available. They repeated the California OSHA Laboratory and NIOSH methods.) Regarding Public Hearing Questions 1 and 2, the report of employee exposures to airborne asbestos during demolition of a portion of an apartment building previously damanged and burned by a light airplane is attached as Appendix A. The stucco was identified as having been sprayed, and as having contained less than one-hair of 1 percent asbestos. In summary', employee exposures during demolition were determined to range from 0.25 to 0.33 fibers longer than 5 microns in length per cubic centimeter of air. Regarding Public Hearing Question 3, if any exemptions should be granted by the Board, it is recommended that employee exposures be limited to, and employee protection be the same as, that specified in Title 8, CAC 5208 Asbestos. 4 19- UCC 013980 Occupational Safety and Health Standards Board Page 2 October 30, 1978 Question 5. Regarding exemptions for products containing "encapsulated fibers," tests conducted by the Health Department indicate that the fibers are not all "encapsulated" during destructive removal, such as sanding or sandblasting, but rather are also found as free fibers. Four studies were conducted, with reports forming Appendices 3 (consolidated report of three studies) and C. In all studies, employees were exposed to asbestos fibers, with a range of 0.1 to 7.1 fibers/cm3 (greater than 5 microns in length). Very truly yours Janes H- Heacock Supervising Industrial Hygiene Engineer JHl/cs enc -20- UCC 013981 .`APPENDIX B TEXTUHED COATINGS OF AMERICA, EJC. Because of Leg!3 lit'ire concern with regard to future worker exposure to the asbestos ccmaimed in asbestos coatings being spray applied, the Occupaticr.il He alia rmrh conducted industrial hygiene ueterminations of worker ere ure to asbestos released from substances (these .materials covered by che exemptiens introduced by SB 1596), previously applied and aged, curir. 5 building renovscicn/repair and demolition operations. Mr. P. Tillisch of Textured Coatings cf America (TCA) agreed to provide appropriate err erturities for sues determinations during typical in dustrial eperarters. This, study involved intermittent sampling ana analytical cete.mirations over a period of several months. Oa three different occasions, the Department of Health, Occupational Health Branch and TCA conducted tests: (1). August 31, 197$ at 1301 Bbccsiticn Blvd., Lcs Angeles, for building interior coatings (2). (3)* November 16, 197$ at 950.S. Broadway, Los Angeles, for building exterior coatings and December 17, 1976 at Village Grove Park in the city of Corona for exterior fence coatings. M5THCD At all three locations sanding or sandblasting was used to simulate building renovation. , At the first location, LcOi Exposition Bird., Lcs Angeles, th< tests for asbestos were conducted inside the building at the end of a h iiwsy which had been partitioned off frcu the rest of the building (to ka< p cust o a rum. The enclosed area was approximately 5 ft wide, 12 ft leng and 3 ft high. Inside the partitioned area an "employee" did the actual sanding. The "employ was Scott Tillisch, an employee of TCA. He was observed by Mr. J. Heacock and fir. L. Beck of the Cccupaticnal Health Brar.ch (CH3) and Mr. M. Ordanik of the Southern California Laboratory Section. The sanding was done with a portable electric hand sender which the operator usea on the wall for approximately 2 hours. Samples were collected in three ways. The first was in the operators breathir xone (CBZ). The second type was an area sample. The area sample utilised the same type of pump and o'iltar-casseuts as the CBZ sample but were located -21- UCC 013982 *id# H532i/cr.:/rr-i APPENDIX B -a- ` 2/23/77 on an "cbser'.mr'* who walked beck 2nd forth throughout the test area. -The third typ: c; su-pi:.. coulee tec. acre "r.atc-riai" zzr:li~* Ihese were collected from the oust alter the 5arming operation by chirpinr material cff the sandpaper face, or from the material off 02' the wall before sanding. At the second "location, 950 So. Braodway, Los Angeles, the asbestos test was conducted in the alley behind the building using 3 cc--erctol sar.d-f blasting machine. An ercterxor wall approximately 10 Seet long was selected and blasted for cost of its length to a height of about 5 feet. Again the three types cf samples were collected. Operator Breathing Zone, area, ar.d material sample. A second OEZ sample on aha .tan running the earn, mixer for the sandblaster was also collected. The area sarnie -was again, collected or. an observer walking back and forth through the blasting area, both upwind and dmwnwird of aha operation. "Material" samples vers fret settled sana-dust or fret building surface chips. The people involved 'were Mr. Scott Tillisch as sandblaster (TCA), Mr. ?.cn Mi as nixer-r.cse tender (TCA), Mr. J. He acock. (03), Mr. L. Heck (CHS) and Hr. M. Crdanik (5c. Cal. Lab) all as observers. Ire area samples were collected on Mr. Beck as he observed the operation. The third location, 'village Grove Park, Corcna, utilized the sane sandblast! equipment as the saccna location. This tire a fence was sandblasted. The fence surrounded a noiil hone development. 5a.--les were taken in the vacant lots (.#'3 19 and 20) cn the worth side 01 the develcpr.ent approrcr.aceiy 30 feet fret the northwest end of the fence. The two lots were appraxar.atsl 50* X 150* combined. Hind out cf the west 3 10 rph. Samples were collected at the sandblasters 03Z, nicer-hose tender's OBZ and area samples upwind and downwind, both stationary and ncoil. At this third location Mr. H. Hhodes ar.d Mr. 3. Ingalls of Union Carbide (New York) represented TCA. as consultants and Industrial Hygienists and collected samples along with the Occupational Health Branch. It was nutuall agreed that Trior: Carbide and the Occupational Health Branch would collect samples side by side. People present were Mr. Paul Tillisch, 7.P. of TCA; Scott Tillisch as hoseteriier-minor; Hen Schorr as sandblaster; Mr. Rhodes and Mr. Ingalls of Union Carbide; and Mr. J. Hinton and Mr. L. Beck of the Occupational Health Branch. Again the air in the sandblaster and mister-hesstender's CHZ's was sampled. Area samples included firmed location samples cn the fence post upwire ana downwind, and roving samples on Mr. Hhodes who -walked back and forth through the area, fettled dust was again collected as a naterial sasple after the sandblasting ceassc. Far a-*^ three iccaticr.s Simla ''Blanks'* ".ere kect for analytical ccmariscn. labcrttcrv analysis utilised CSHA and HICi{ ancroved methods. '* . / H O r-~ J'-0Q 22 UCC 013983 APPEMDIX B_ _ --inr?5^i/o^/7,vi -3- February 23, 1977 Data; locatio:: i 1901 Snpcsiticn .-4 Sander Area Fibers/cc 1.7 0.3 5 Microns 1.1 0.9 Both samples simultaneously* within 10 ft of s; * in length 0.5 0.3 0.2 Material - Chrysotile fecund in matrix: Free fibers released "with grinding abrasion - Latex Base Paint (Vinyl-Acrylic) tjocatic:: 2 Fibers/cc 5 Microns 950 South Broadway, Los Angeles SandblasterMirgr-Hcsetender. Area 1.5 (filter outside of hood) 2-i _______________ 0.4 0.7 1.6 All 3 sampled simultaneously* 1.2 __________ Material - Aldyd Base; 3-5# Chrysotile .Asbestos Within 15 to 20 feet of source LOCATTOl 7 Village C-rove Park (Lots 19 end 20)", Ccrcna aster M- xer-Hcse tender i-- --------- - - ----- - - - ----- - - - Before Blasting 0.3 (Stationary Backgrcu Upwind 0.2 (Moving Background) Fibers/cc 0.1 (Stationary 3acksrcu Uovrind* 5 Microns 1.6 (Filter outside nf hood} 1.4 0.1 (Moving during blast 'lever do.nvnnd 7.X AA " - 7 (Filter inside J* ' rtf Vrtr/i 1 _ , (Filter outside 2#1 Of Hood) 2.2 fa-wind) 2-* " 0.2 " rt " " * 1.9 (Stationary during b1 'Stirr) Cc*..T.'.'*.r.' Material - IT' Chry-cctile Epoxy case? -23- * Within 20 to LQ feet of 103504 UCC 013984 .APPENDIX B ID? H5323/^V77:! * ^4- February 23, 1977 * Horizontal Hr.?3 distinguish those samples collected -in the 3are time frame and/or simultaneously. Variables: ALL LOCXTIC:^ Several variables were not accounted for in the study concerning all three locations. First the sanding r-tdiun was not analyzed for asbestos. At locatic 1, this would bar been the sandpaper used and, at locations 2 and 3, the sand used' far sandhi as zing, Secondly zhe building r.azerial on which the tsxzurea coating had beer, applied was nsz analyzed for asbestos content. At the first location this urn Id have been the wall plaster, the second location, a stucco wall reinforced - ith wood, and the third location a metal fence. Thirdly, the area sarnies *.-tried in distance from the source and were not constant with regard to wind dir ection e.xeeot in a few instances. Finally, no ''before" and "after" air sarnie s were collected to establish an ambient asbestos concentraticr., enter t at the third location. Ambient air samples at the third location revs alec :at there is asbestos from uuxr.cwn smarcss contaminating the air which nan be the subject os' an environmental study. However, in view of these variables, we feel the results would be changed insignificantly had they been acccum ,ed for. The bag -was labeled "ICOTs sand"; the sandblasting went crly to the su face of the plaster, stucco and metal; and the chemist who analyzed the sam les is an experienced expert in the field of asbestos determinations. R5SULTS Die data.shows that there is a definite exposure to asbestos when employees or workers sandblast cr sand coatings containing asbestos and that this exposure is present in the immediate area. In this case, the i--eclats area referred to is within a 10 foot radius of the source in a nor.-wir.dy condition, and with in a 40 foot radius downwind in vrindy conditions. In any case, at all three lccaticns there was an employee exposure of at least 1 fiber/cc, and up to L fiter/cc as an average. The area samples also shewed exposure into the 1 to 2 fiter/cc range. And finally the mixer-hosetender exposure range was from 0.5 to 2.0 fibers/cc. discussion Die current standard for asbestos is 2 fibers/cc greater than 5 ricrcns in length. However, medical monitoring is required at 1 fiber/cc an an d hr. time weigited basis. Since the results indicate ernlcyee exposure to 1 fiber/cc and greater, we conclude that mere is a high possibility of harmful exp enures to employees during builtj-.g renovation. -24- A^S50vS UCC 013985 APPENDIX C ASBESTOS SAMPLING DURING COATING DESTRUCTION Many questions have been raised regarding the levels of asbestos fibers released during the removal of paint type coatings containing asbestos. In this investigation, air samples were collected during the destruction of a high performance coating containing 2.1% asbestos. A AO foot diameter, 25 foot high steel tank spray coated in 1973 was sandblasted to bare metal. Since sandblasting represents an extreme condition, it provides an estimate of the highest employee or community exposure to asbestos. METHOD Air samples were collected in the breathing zones of workmen using personal sampling equipment. Open face filter cassettes containing 37 mm Millipore AA filters on a cel Ininse backing pad were attached to the employee's respirator straps or lapel. MSA Model G portable sampling pumps were used to maintain a flow rate of 1.5 liters per minute. Flow rates were calibrated in the field with a Brooks type 1355-01A1AAA rotameter. Sampling times varied from 5 to 15 minutes. Thirty minute background samples were collected before sandblasting. Unexposed blanks were also submitted. Samples were collected on the three workmen, two sandblasters and one pot tender. Sandblasters wore airline respirators to protect them from silica exposure. ANALYSIS Asbestos sample filter cassettes were sealed in the field, packaged and forwarded to the U. S. Department of Labor, OSHA Laboratory in Salt Lake City for analysis. Samples were analyzed by phase contrast microscopy. Selected samples were also analyzed by dispersion staining and electron microscopy. Results of the laboratory analysis were forwarded as soon as they became available. The optical microscopic results are summarized in Table 1. Asbestos fibers were counted by the standard NIOSH method. ELank sample cassettes submitted with the asbestos samples were optical methods. -25- UCC 013986 APPENDIX C Three unused filter cassettes were submitted. No fibers were detected on two filters, one filter was reported to have 0.01 fiber/field (100 fields counted). Background samples collected before sandblasting were reported below the detection limits for asbestos. In addition, JK-32, collected during sandblasting of a section of the tank sandblasted to bare metal earlier in the day was also reported as below the detection limit for asbestos. To gain additional information about the fibers present, filters were further analyzed by dispersion staining. In a study of sample JK-3 by dispersion staining, 16 of 110 fibers were identified as chrysotile asbestos. Other samples were stained. The fibers present were found similar to JK-3* The nonasbestos fibers were identified as plant fibers and fiber glass. RESULT Time weighted average concentrations were calculated from the optical microscopic analysis. Exposures to the workmen are listed in Table 2. Sandblaster TWA exposures were calculated O to be 0.2 and 0.3 fiber/cm . The pot tender's average was 0.1 fiber/cm^, greater than 5 ;a in length. DISCUSSION Enployee exposures were within the present Cal/OSHA standard of 2 fibers/cm , greater than five microns in length. In addition, workers with the greatest asbestos exposure were protected by the airline respirators worn to prevent silica exposure. Sandblaster #1 did not sandblast all day. His calculated time weighted, average, 0.2 fibers/cm, represents a partial day of sandblasting. Sand blaster #1 was not used between 13:15 and 15:30. Asbestos fiber counts of mixtures of air contaminants containing asbestos are slow and tedious. The standard phase contrast optical microscopic UCC 013987 *0850? APPENDIX C method was relied upon to determine worker exposures. In this method of analysis, the procedure allows for information gained through additional testing to be used to more precisely identify countable fibers. The analyst may reject fibers identified as not being asbestos. Dispersion staining and the use of cross polarizing filters, or a first order red retardation plate, give additional information regarding the nature of the fibers. Fibers without the correct morphology or other characteristics, recognized as not asbestos, are not counted. Fibers of doubtful identity are included with the asbestos count. The results of electron microscopic analysis and dispersion staining quantify the proportion of the total fibers which are actually asbestos. These percentages were between 12 and li$. Although the percentages are small, it is important to note that free asbestos is released. Analysis of blank samples ruled out the possibility of significant contamination from either the blasting sand or desert air. /flw 10/19/78 -27- UCC 013988 APPEN'DIX c Table X SAMPLE # OPERATOR TIME OH JK-1 Sandblaster-1 3:21 JK-2 Pot Tender 8:21 JK-3 JK-4 JK-5 JX-6 JS-7 JK-8 Sandblaster-1 8:5k Pot Tender 8s 5k Sandblaster-2 9:09 Sandblaster-l 9:1k Sandblaster-2 9:20 Pot Tender 9:26 JK-? JS-10 JK-11 JK-12 JK-13 JK-14 JJW5 JX-16 J*-17 JX-18 JE-19 JX-20 JE-21 JK-22 JX-23 UK-24 JK-25 Pot Tender 9:k6 Blank _ Sandblaster-2 9:36 Sandblaster-2 9tLl Sandblaster-2 9:k7 5andblasttr-2 9:55 Sandblaster-2 9:55 Pot Tender 9*58 Sandblaster-2 10:01 Sandblaster-2 10:07 Sandblaster-2 10:13 Pot Tender 10:20 Sandblaster-2 10:24 Sandblaster-2 10:34 Pot Tender 10:43 Sandblaster-1 10:47 Blank TOTAL TIME (MINUTES) 27 27 A 20 32 U 17 16 20 12 5 6 5 6 12 22 6 7 10 22 10 18 16 16 FIBERS/CC 4D.L. <, D.L. 0.49 0.35 Membrane marred 0.57 0.31 No membrane in cassette * <D.L. None O.63 0.71 1.4 1.6 0.75 0.17 < D.L. 1.3 0.3 0.24 0.32 0.91 1.02 1.27 None COMMENT Background (Desert Air) Sample before sand blasting Background (Desert Air) Sample before sandblasting Under Blasting Hood. Two Sand Blasters working Hlasting at ground level On Scaffold. Ground Level Two Blasters working Two Blasters working Ground Level Ground Level Ground Level Ground Level - Overlap JK-1! Hole in filter - Overlap JXGround Level BLaating i of sample 1 11 minutes break Entire sample break On man lift On ground A85Gg ft CO CM 1 UCC 013989 APPENDIX C Table 1 (Continued) SAMPLE # JK-26 JK-27 JK-28 JK-29 JK-30 JX-31 JX-32 jx-33 JK-34 JX-35 JK-36 JK-37 JK-38 JX-39 JK-40 operator Sandblaster~2 Sandblaster-1 Pot Tender Sandblaster-1 Sandblaster-2 Pot Tender Sandblaster-2 Sandblaster-2 Sandbl2ster-1 Sandblaster-2 Sandblast er--2 Sandblaster-2 Sandblaster-2 Sandblast er-2 Sandblaster-2 TIME ON 10:52 11:01 11:00 11:07 11:09 11:18 12:50 13:04 13:09 13:17 13:24 13:34 13:48 14:06 14:17 JK-41 JK-42 Sandblaster-2 Sandblaster-2 14:35 15:00 JX-43 JX-44 Sandblaster-2 Blank 15:21 TOTAL TIME (MINUTES) FIBERS/CC 16 4 D.L. 6 0.36 17 0.40 11 0.67 14 0.45 8 < D.L. 5 4 D.L. 11 < D.L. yC 0.95 7 . 0.60 9 0.66 14 < D.L 17 0.32 11 0.19 17 0.40 25 0.23 21 No count possible 15 0.46 0.01 COMMENT On lift above #1 #2 above on lift #2 still above Blasting time: 9 min Blasting Bare Metal Area. Man lift Ground On man lift Blasting time 6 min On lift On lift 7 min blasting Lift 11 tain blasting Lift Lift Blasting over operator's head (cat walk) Lift 15 min blasting Lift Lift 11 min blasting fibers/field (100 fields) D.L. Detection Limit All samples Operator Breathing Zone -29UCC 013990 4 5 /c APPENDIX C Table 2. Pot Tender SAMPLE JK-2 JK-4 JX-8 JK-9 JX-16 JK-20 JK-23 JK-2B JK-31 Unsampled TIME(Min.) 27 37 20 12 22 22 17 18 8 182 Time Weighted Average Aebestos Exposure. C3 FIBERS/C5T 0 0.35 No count 0 0.17 0.24 1.02 0.40 0 0.28* CALCULATIONS * Average Exposure * CT =* concentration AT o' unsampled. TWA a f CT 480 =97.5 480 = 0.20 3 * 0.2 fibers/ca , >5 C =* fibers/ca^ T = Time (minutes) Sandblaster. #1 Partial day time weighted average. SAMPLE JK-1 JX-3 JK-6 JK-24 JK-27 J5-29 JX-34 TIME (Min.) cj FIBBRS/Clt 27 0 20 0,49 17 0.57 16 1.27 6 0.88 11 0.67 5 0.95 CALCULATIONS ' No exposure between JK-6 and JK-24.. TWA = (C? * 57.2 a 0.1 f/cm^, 480 480 >5fi C fibers/ca9 T-- Time (minutes) -30- tJCC 013991 4S 5-; i APPENDIX C Table 2.TlCcr-timed) Sandblaster 2. Time Weighted Average Aabeatoa Exposure. SAMPLE TIME {Mia.) 0 ?IBERS/CM3 JX-5 jr-7 JK-ll JZ-12 jr-13 JX-14 JX-15 JE-17 Ji-ia JX-19 JK-21 JK-22 JX-26 . JK-30 JI-32 JX-33 JK-35 JI-36 JX-37 JX-38 JX-39 JZ-40 JX-41 JK-42 JX-43 Unsampled 11 16 5 6 8 Overlap 12 Overlap 7 10 11 18 16 17 5 11 9 9 15 17 12 17 12 17 25 52 Average Exposure Marred 0.31 0.63 0.71 1.4 JK-i5 0 JK-15 1.3 0.3 0.32 0.91 0 0.45 0 0 0.6 0.66 0 0.32 0.19 0.40 0.23 Ho count 0.46 0.38* CALCULATION * Average exposure = CT = concentration if of unsampled TWA > CT 480 = 130.4 - 0.27 480 0.3 fibers/cm3, >5 ju C = Concentration (fibers/cm3) T = Time (minutes) A0&5io -31- UCC 013992 AIRBORNE ASBESTOS COUNTS for Textured Coatings of America, Inc. (Village Grove Trailer Park, Lots 19 and 20) Corona,.California Date Sampled: December 17, 1976 Date Reported: April 1, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: B. L. Ingalls & G. J. Spencer Union Carbide Corporation Reported By: H. B. Rhodes Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York a85!3 -32- UCC 013993 OBJECTIVE 1- - To measure the airborne asbestos fiber concentrations generated during the removal of an asbestos-containing maintenance coating from a sheet metal fence by sand-blasting. DESCRIPTION OF OPERATION The test was run at Village Grove Trailer Park, Lots 19 and 20 in Corona, California. The park was surrounded by a galvanized metal fence about 5' high that had been painted about five years previously. The metal was first primed and then painted with an alkyd-based maintenance coating containing about 5% asbestos. The paint also contained mica, talc (non-tremolitic), fiberglass, and perlite. The sandblasting was done with a portable unit consisting of a compressor and a blasting unit. The latter had a sand storage tank about 1' in diameter by 3 1/2' long which fed silica sand through a lever operated control device and a heavy hose to a blast nozzle, under the control of the operator. One man handled the blasting nozzle while the other operated the compressor, assisted with the hoses, but primarily operated a lever on the sand delivery unit to keep the sand flowing. The nozzle operator wore a conventional sand-blasting hood with air openings on the sides. During the blasting operation one man stood about 2' from the fence and moved the nozzle, held about 3-6 inches from the fence, in short arcs until the impinging sand removed the paint down to the base metal. Bonding was excellent and it took at least several passes of the blast to remove the paint. The material removed was finely pulverized. The bottom 1 1/2' of the fence was not hand-blasted to avoid raising extraneous dust from the dry ground at the base of the fence. The weather was clear and warm with a light, variable breeze blowing from left to right in approximately the same direction as the fence. SAMPLE COLLECTION The following types of samples were collected during the test: 1. Background samples prior to testing were collected at the fence,~4 1/2' from the ground about 100' apart. (Spanned the section to be sand-blasted.) (G-16 & F-44) 2- A sample about 40' downwind, on the fence about 5' above the ground, during the last 25 minutes of sand-blasting.(G-3) 3. Personal samples on an observer in an area generally 25-35' from the blasting operation and approximately perpendicular to the blasting. (A-86, A-81, J-89) 4. Personal samples on both the helper and the sand-blasting operator. All operator samples were external to the hood except X-2. Helper - G-48, X-8, C-15, X-4 Operator - D-71, X-14, G-34, X-2, X-3 A Qp c , '4 ______ -33- UCC 013994 2- - COUNTING EQUIPMENT AND PROCEDURES All samples were collected with battery-powered air pumps (M.S.A.), calibrated to 2 liters per minute on Mi11ipore membrane filters of 0.8p porosity. The samples were mounted and counted in accordance with the procedure of Bayer, Zumwalde, and Brown (Bureau of Occupational Safety and Health, February 1969). Counting was done with a Nikon microscope at 400X utilizing a Poton reticle with a 0.0062 mm2 field area. One hundred fields were counted for all samples. These samples proved to be particularly difficult to count. Out of the total of nine personal samples from the blast operator and the helper, six were loaded with dust to a level where filter areas were frequently obscured. When such an area occurred, the counter went on to another field. There is no way to tell how this may have influenced the results. Our normal practice in this situation is to resample, but considering the difficulties this would entail, the filters were used. In addition to this problem, the nature of the samples puts an extreme strain on the method. Thus: 1. Fiber concentrations were low with 0.38 fibers/field the maximum and 0.2 fibers/field more or less typical. This is well below the 1-5 fibers/field range recommended by NIOSH. 2. The fibers counted were in the 5-15y range so that the `'5m decision" was a frequent requirement. 3. There were substantial concentrations of mica "chips" present. These can generally be recognized as not asbestos but certain shapes around 5y in length can become undistinguishable. These factors of low fiber concentration on the filter, filter size distribution, and potentially interfering "fibers" result in a high degree of operator discretion in the determination of the total number of asbestos fibers counted. When this possible variation is combined with the short sample times substantial variations can result. In view of these uncertainties, a modification was made in the procedure to report two categories of fiber: 1. Obvious chrysotile asbestos. Either long and curved, or distinctly thin and slightly curved in the 10-20y range. 2. Possible asbestos fiber: Particles which did not have obvious identifying asbestos features but met the L/D >3, >5y require ments and were dark and fiberlike under phase-contrast illumination. When there was any doubt about a fiber's identity, it was included in the appropriate class. The total of both classes would be the value ordinarily reported as asbestos. Particles which were obviously not asbestos were not counted. This would include such things as unbroken fiberglass, mineral flocks with non-parallel sides, and particulate that appeared bright under phase contrast. It should be noted that the only known source of asbestos in this formulation was the 5% by weight chrysotile. (Note that the 2% asbestos figure reported by DOSHA in Appendix B is in error.) b -34- UCC 013995 -3- RESULTS AND DISCUSSION A description of each sample and the respective fiber concentrations are shown in Table I. The data obtained by Counter A are presented graphically in Figure I. Where paired results are available Counter B was high six times and Counter A three times. The differences, without regard to sign ranged from 0.1 to 1.1 fibers/cc and averaged 0.3 fibers/cc. In view of the counting difficulties on these slides we consider this to be good agreement for operators in the same laboratory counting the same slides. The operation of the sand-blasting equipment was too erratic to provide a meaningful estimate of operator TWA exposure for normal oper ation. Using just the time periods during the actual blasting operations, the time-weighted averages were: Operator - 2.2 fibers/cc >5u Helper - (10)(1.03)+(23)(1.1)+(14}(0.15)+(22)(0.06) a 39,02 a Q g fibers/cc >5u (10)+(23)+(14)+(22) 69 TlDers/cc The measured TWA exposure for this particular 8-hour day would then be: Operator - - = 0.3 fibers/cc >5y Helper - 39^02 a Q Q8 fibers/cc >5u -35- UCC 013996 *0 G -4- TA91C 1 SUtVUtf OF AIRnOR.VE ASOfSTOS F1M* COUNTS nuKlKC nr.SAHO-BIASIIHG Of ASr.[-STUS-CCMl A UUr,J KAlllTEHAflCE COAT Description of Operation Semole Data lime Tot.) *0. On Off Min. Pretett Controls On fence* left side of area to be sand-blasted. --4 1/2* above ground. Oft fence, -,I00* from 6-16. above ground. 6-16 10:35 10:56 21 f-44 10:4? 10:59 17 Personal sample on observer ~2S* from fence and moving parallel to fence. A-86 10:39 10:52 13 Observer (During Sand-Blasting) Personal senple on observer A-ai --20-30' from fence and moving parallel to fence. 11:12 11:25 11:18 11:27 Same as A-81. J-89 12:26 12:52 Area sample on fence. 5* 6-3 above ground and down wind. (In lieu of observer) 1:35 2:00 6 2 8 26 25 Airborne Fiber Concentrations (fibers/cc >5u) Obvious Chrvsotile fibers 100 fields f/cc Operator "A* Possible Asbestos fibers 100 fields f/cc Total Asbestos fibers 100 fields f/cc Operator "B" 13T3-- Asbestos fibers 100 fields f/cc 00 2 0.07 2 0.07 00 00 00 00 2 0.11 00 2 0.11 2 0.08 4 0.21 1 0.09 1 0.09 00 1 7 0.19 22 0.03 0.61 1 29 0.03 0.7 21 0.6 Comments Helper tDurlnc Sand-Blasting) 1 a* CD Personal snpl. Assisting with hoses. Operating sand feeding equipcent. 11:10 11:18 8 11:24 11:26 2 Iff Sene es 6-48. 1-8 12:25 12:43 23 Sene es G-48. Sene es G-4S. C-1S 1-4 1:08 1:36 1:22 14 1:58 22 1 0.07 14 0.97 15 1.03 9 0.6 10 0.30 18 - -- 1 0.05 2 00 2 0.54 - 0.10 0.06 28 45 3 2 0.84 1.35 O.IS 0.06 60 9 1.B 0.3 Heavily toaoed; ha tP count second si Blasting Operator IPuring Sand-Blasting) Personal s.-p!e. Operator handling sand-blasting notrle. standing--2' fro fence. 0-71 11:10 11:18 8 11:24 11:26 2 Sara es 0-71. 1-14 12:2S 12:36 11 Sew es 0-71. 6-34 12:38 12:46 8 Sene as 0-71 except Inside of hood. Sera as 0-71. 1-2 1:08 1:22 14 1-3 1:36 1:58 22 7 0.48 2S 1.72 32 2.21 13 0.82 30 - S 0.43 33 8 0.39 26 21 0.66 35 1.88 - 2.84 1.28 1.10 43 58 38 34 56 2.70 3.64 3.28 75 39 1.68 - 1.76 S3 Heavily loaded, ha to count. 4.70 3.36 - Heavily loaded; ha to count second si Heavily loaded; ha to count. ft * 1.66 Affs -36 UCC 013997 OF ASBESTOS-CONTAINING HAIHTEHAHCE CGAT1HC UNION CARBIDE CORPORATION METALS DIVISION P.O.BOX 579 . NIAGARA FALLS, N.Y. 14302 TEL: 716-278-3376 January 13, 1978 Mr. James Heacock Occupational Health Section California Department of Health 21 SI Berkeley Way Berkeley, CA 94704 Dear Mr. Heacock: The suggested protocol for the cooperative test that we discussed in your office is attached. As you requested, it has been set up so that the Department does the actual sample collection. Plans are well along to conduct the test on one or more large tanks in the Trona area that have been coated v/ith zinc-rich primer. The only hold up is satisfactory verification of composition of the primer. We would like to go ahead and plan to conduct this test during the week of January 23, 1978, preferably on Tuesday the 24th. Please let me know if this is satisfactory so we can finalize on a date and the other arrangements. In view of the time that has passed since the original hearings and the number of new people involved, it seems appropriate to comment on two questions relevant to the previous testing results reported in a letter of June 1, 1977 from Jerome A. Lockner, M.D. to the Honorable Jack R. Fenton, i.e.: T. The appropriateness of sandblasting as a representative test method. 2, The accuracy of the previous counts. We have been informed by a large manufacturer of the high-performance mainten ance coatings of particular interest here that certain of these coatings are sandblasted as a routine procedure. Usually it is a light "brush" blasting to remove rust spots and loose coating but occasionally complete removal takes place. Sandblasting thus represents an extreme condition and should thus be a reasonable way to approximate the upper limits of exposure. -38- UCC 013999 Hr. James Heacock -2- January 13, 1978 As we discussed several times, in the test where Cal/OSHA and Union Carbide collected side-by-side samples during a sandblasting operation, both laboratories found asbestos counts of several fibers/cc or wore when counting by the routine NIOSH procedure. It is well recognized that the procedure has very serious limitations for dusts of the type generated during sandblasting. Subsequent examination by Union Carbide of several of the filters using scanning electron microscope techniques suggested that both laboratories may have counted substantial numbers of non-asbestos particles as asbestos and that free asbestos fibers were extremely rare. Over the past year the Federal OSHA Laboratory at Salt Lake City has adopted more sophisticated optical techniques to distinguish asbestos from other particulate matter and are quite possibly the most skilled laboratory in the country in this area. I have discussed our problem with the Director, Hr. Floyd Madsen, and he is agreeable to count a reasonable number of samples. It will be appropriate for you to make a written request for this assistance at the time the samples are submitted. Please let me know if you have any problems with this proposal. Vie are looking forward to participating in what appears to be the first carefully defined test of asbestos exposure in this type of application. It was a pleasure meeting with you and the others in Berkeley. Very truly yours, - /3. Harrison B. Rhodes Technology Manager HBR/rmm Attachment -39- UCC 014000 TEST PROTOCOL OBJECTIVE The objective of this test is to measure the airborne concentration of asbestos fibers generated during the removal of a non-resilient maintenance coating by sandblasting. The site selection, test operation, sample collection, and sample analysis will be carefully planned in advance so that meaningful results are obtained. WORKING ARRANGEMENTS The selection of the test site and provision for the sandblasting operator and equipment are the responsibility of the Union Carbide Corporation with the choices subject to approval by the Department of Health. It is intended that the Department of Health and Union Carbide will each have at least one qualified person at the site to work out a mutually acceptable sample collection strategy in accordance with the general guidelines under "Sample Collection Strategy". Sample collection will be performed by the Department of Health. After collection is completed, a validated summary sheet of the collection data will be prepared with a copy for both participants. In order to expedite matters, the cassettes will be packaged and sent immediately by registered mail to: Mr. Floyd Madsen, Director OSHA Laboratory 390 Wakara Way Salt Lake City, Utah 84108 The Department will send a confirming letter to Mr. Madsen requesting them to analyze the samples. He has been alerted and is expecting to receive 10-30 samples. When analysis is complete, the OSHA Laboratory will provide both participants with a copy of the results. TEST SITE AND OPERATION CRITERIA The following criteria apply to test site selection: 1. Reasonably representative of a substantial commercial use of the product. 2. Large enough to allow for several hours of dust generation. 3. Reasonably unambiguous definition of the composition of the asbestos-containing material being handled and an asbestos content in the upper part of the range of contents of interest. 4. Sandblasting will be done with regular commercial equipment and materials by a professional operator in a manner that is comnercial practice. - ^^ I -40- UCC 014001 -A -2- - SAMPLE COLLECTION STRATEGY As noted previously, it is intended that the Cal/OSHA and Union Carbide representatives at the site work out the most appropriate sampling strategy with the following special provisions to be met: 1. Personal breathing zone samples will be taken on the operator and the helper (if present) that are subject to the highest exposures. In addition to samples collected during the actual operations, a reasonable number of samples will be collected before and after operation to permit an estimate of the 8-hour time-weighted average exposure. 2. Area samples upwind and downwind will be taken before, during and after the dust generation operation. ADDED NOTE The Union Carbide Corporation is participating in a national round-robin study of the NIOSH collection and analytical procedure. It has been agreed that we may have an observer wearing a pair of pumps moving in the immediate vicinity of the dust generation operation. Care will be taken that there is no interference with the test. These samples will be entered into the round-robin and since they will be counted by only the standard NIOSH procedure, the results are not relevant to the present tests. SAMPLE ANALYSIS All sample cassettes will be shipped unopened to the Federal OSHA Compliance Laboratory at Salt Lake City. 8S2'> -41- UCC 014002 XTXA\ G( PREPARED TEXT ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD AUGUST 30, 1979 TITLE 8: GENERAL INDUSTRY SAFETY ORDERS (Asbestos) Held in San Diego, California on August 30, 1979 Union Carbide Corporation Metals Division Niagara Falls, NY 14302 UCC 014003 408523 Introduction My name is John L. Myers and I am employed by Union Carbide Corporation as Marketing Manager for its "Calidria" asbestos products. Union Carbide pro duces about 30,000' tons per year of asbestos fiber from a mine and mill located in the King City area of California. The operation employes approximately 70 people with an annual payroll of nearly $2,000,000 and is the largest industrial employer in a radius of about 50 miles. We produce and market raw asbestos fibers for industrial use but do not manufacture finished asbestos-containing products. Our plant has had complete air monitoring and medical surveillance programs since operations were initiated in 1963. Our interest in the proposals to change the "action level" for monitoring and medical examinations is because these changes can have a massive impact on the users of asbestos-containing products with, we believe, little or no gain in worker protection. Changes in Section (8) - Monitoring and Recordkeeping The staff proposes to reduce the level in paragraph (g)(1)(A) at which monitoring is required from 1 fiber/cc >5y to 0.1 fiber/cc >5y. The question of the appropriate "action level" to trigger monitoring and also medical examinations was discussed at the standards Board hearing on April 26, 1979. At that time, there was general agreement among labor, industry, and even state governmental representatives that a level of 0.5 fibers/cc longer than 5p was reasonable. This level was based on considerations of worker protection, ability to measure, and an efficient allocation of professional resources. This level was adopted unanimously by the Board. UCC 014004 A08524 -2- Subsequent to this action, on May 10, 1979, the Federal 05HA Regional Administrator, Mr. Gabe Gillotti, informed Mr. Don Vial by letter that this action by the Board was "unacceptable . . .Your asbestos exposure language will need to be identical to Federal OSHA" and quoted OSHA Program Directive #300-16 as the basis for this requirement. Mr. Gillotti's letter was a surprise since California has a state plan which has been fully approved "as effective as" the Federal regulation in accordance with Section 18(e) of the OSHA Act and under Part 1902 of the imple mentation regulations. There has been no change in the Federal Regulations. 19CFR 1910.100 1 (j)(2), (3) or (4) which would require their incorporation into the State Regulations in accordance with Section 18 of the OSHA Act. We discussed this with John W. Whittlesey, Esa. a Union Carbide Counsel specializing in OSHA matters. He has authorized the following opinion and will be glad to provide a written confirmation if the Board desires one. 1. Program Directive #300-16 is an administrative interpretation only. As such it does not have any regulatory or statutory authority. 2. California may elect to modify their regulations to conform but are under no statutory requirement to do so. 3. Failure to conform to such an Administrative interpretation does not provide the "substantial evidence" required under Section 18(g) of the OSHA Act to sustain a withdrawal of certification. 4. The authority delegated to the Regional Administrator under paragraph 1953.4 (a)(2) relates to inconsistent interpretations of standards as they exist. It does not require standards which have been certified "as effective as" to be modified to conform identically. UCC 014005 A 08 52 5 -3- California is not required to change their present regulations to conform to the Federal wording. The choice is up to the Standards Board. There are at least two reasons wijy the Board should retain the present action level of 1 fiber/cc or at most lower it to 0.5 fibers/cc. 1. The very large burden on resources to comply with (and enforce) a 0.1 fiber/cc level. 2. The inability to measure the airborne concentration at this very low level. Significant releases of asbestos fiber must take place before the 1 fiber/cc >5u current action level is exceeded. It is fairly easy to ascertain where initial monitoring does not need to be conducted and unnecessary action can be minimized. If, on the other hand, the California Asbestos Standard is changed to require monitoring at a level of 0.1 fiber/cc, virtually every place of employment where asbestos is present in any form must be monitored at least once. Brake repair shops provide a specific example of the scope of the problem. Molded brake linings contain asbestos. Airborne fibers can be re leased when they are sanded, machined, or when the drum is blown out with com pressed air. It has been shown that airborne asbestos concentrations can be controlled to low levels by careful handling, proper work practices and the use of vacuum cleaners to remove dust. There are over 20,000 brake repair shops in California, the majority of which are service stations. A survey of 100 shops was made by CAL/OSHA some months ago and it is our understanding that it was found that a low level of airborne fiber is common but exposures above one fiber per cc are rare. Generally, the higher levels occured at the large truck repair shops where such things are blowing and sanding have been practiced without proper dust control. If the proposed action level is adopted, all of these shops, which are generally small businesses, would be reguired to monitor at least once. A08526 UCC 014006 -4- We recently asked two industrial hygiene consulting laboratories the cost to conduct a basic "initial monitoring'1 for a relatively simple opera tion like a brake shop. Both gave a range of $300-$500 per test. These figures do not include travel and living expenses or provide for any significant extra technician travel time to the test site which can occur frequently. Applying a representative value of $400 to the approximately 20,000 registered brake shops gives a cost of $8,000,000 added to the operating expense of this industry to comply with the new regulation. Each inspection would also use up about two man-days of the time of trained personnel. If we assume 200 man-days as equivalent to a working year, it would take the full-time activity of 200 trained technicians to carry out the monitoring in a year. We doubt if this quantity of people and equipment is available. The main information obtained from such a massive test program would be that exposures are generally above zero, and below one fiber/cc, which is already quite well established. This discussion has emphasized brake shops because they are a well defined entity, already registered and identifiable. The same problem exists for the widespread low exposure in the less well defined construction industry. There is also an additional compounding factor in construction in that the "place of employment" changes a number of times a year so that continuous moni toring at frequent intervals would be required. The brake shops may really be only the tip of a very large iceberg. Changing the initial monitoring action level to 0.1 fiber/cc would place a very heavy cost burden on the employer, require a massive use of limited technical resources in an area of low exposure and consequently low risk, and give a very questionable return in terms of worker protection. We recommend that your present standard be retained. UCC 014007 408527 -5- The second reason not to change to a 0.1 fiber/cc action level regards the ability to measure this concentration and I would like to ask my colleague. Dr. Rhodes, to discuss this aspect. (j) Medical Examinations The staff has proposed that the requirements for medical examinations be changed from the present one fiber/cc TWA "action level" to 0.1 fibers/cc >5u as an eight-hour time-weighted average. It is instructive to continue with the brake shops as an example of the potential impact of the proposed regulations on this small-business oriented industry. It has been our obser vation that a local filling station is likely to have a couple of young mechanics who handle the brake repairs along with other general repair work. The larger franchise type shops may have a dozen or more people who repair brakes with some frequency. For estimating purposes, it will be assumed that there will be two persons per shop for a total of 40,000 persons requiring pre-employment and annual medical examinations under the new proposed regulations. This does not allow for employee turnover. Dr. Clark Cooper, who supervises the joint union-employer medical surveillance program for Western Department of the Asbestos Workers Union, has provided an estimate of $60-75 per man for a minimum physical examination to satisfy OSHA requirements. This is on a large-scale contract basis conducted by well qualified personnel. Examinations of an individual or small groups, as would probably be the case for brake repair shops, would increase the costs to approximately $100 each. These costs do not include time spent away from the job to obtain the examination. At a conservative $50 each, the medical examinations could cost $2,000,000 annually and, obviously, double this to $4,000,000 annually at the UCC 014008 4oe5 28 -6- higher unit cost. This discussion, as with monitoring, emphasizes the brake shops. The less well defined construction industry is faced with the addi tional complications of a transient workforce and moving workplaces. Although this is clearly a very large cost burden, the fundamental question is not the cost per se, but what is accomplished in terms of worker protection. Although it is admittedly controversial as to what exposure level is "significant", we believe that the present California level of one fiber/cc TWA, or some level in that general vicinity, such as 0.5 fibers/cc is reasonable and meets the California objective of a standard which is enforceable and makes a positive contribution to worker health. The lowering of this level to 0.1 fiber/cc would require a large new investment in time, money, and .people by both the employer and the state compliance operation for which we see little if any return in terms of worker protection. We urge you not to make this change. General Comments 1 - Why are the proposed changes a unique problem in California? It has been noted several times that the proposed changes would make the California standard the same as the Federal standard which is administered by the Federal Government in 26 states. The very legitimate question has been asked as to why a standard which has been in effect for seven years will present a serious problem if it is now adopted in California. The answer is basically very simple; although the Standard has been in effect for seven years there has been almost no Federal enforcement in the asbestos product user areas that would be most seriously impacted by the 0.1 fiber/cc UCC 014009 -7- action level. This would no longer be the case in the more comprehensive California state industrial health activities, so we believe that the compliance and enforcement problems described earlier would soon become clearly evident. The statement on Federal enforcement is based on a computer printout of all Federal asbestos inspections over a 30 month period from October 1976 through January 1979 that was supplied by OSHA to the Asbestos Information Association/North America. Details are included in Attachment I. In this 30-month time period there was a total of 17 inspections, of brake repair operations basically on large auto dealerships, relative to asbestos. There are about 250,000 brake shops in the country with roughly half estimated to be in states where Federal OSHA is the primary compliance enforcement. The construction industry has also been mentioned in connection with enforcement and potential impact. The U.S. Department of Commerce^ published a census of the construction industry for 1972 which showed a total of about 430,000 construction establishments with an employment of about 3,500,000 construction workers. It is not well defined how many of these establishments use asbestoscontaining materials and at how many locations per year they work. Considering that over 60% of the asbestos used in the U.S. is in construction products, the number of both people and work locations could be substantial. The printout mentioned earlier shows a total of 173 asbestos-related inspections in the construction industry in the 30-month period. Considerably more time has been spent in the construction industry than in brake shops to make general inspec tions but it is clear that only a minute fraction of possible asbestos containing locations has been inspected. It should be emphasized that the information presented is not intended to be a criticism of the Federal activities or the allocation of the resources UCC 014010 -8- that have been made available to them. OSHA has statutory priorities to consider. It is provided to document the fact that regardless of the reason, the brake repair industry has been subject to virtually no enforcement of the 0.1 fiber/cc action level requirement for monitoring and medical examin ations, and the situation is little different in the construction industry. There is no evidence that these provisions are reasonable and workable in the states under Federal administration since they have not been actively enforced on a wide basis. In contrast to this, the State of California has supplemented their OSHA activities with the Carcinogenic Substances Control Act, a registration provision, a Carcinogens Control Unit, an active consultation program and an experimental voluntary labor-industry joint program. We believe that the incorporation of a 0.1 fiber/cc triggering level into this comprehensive compliance program would soon reveal the gross impracticality of such a level and urge that it not be done. Concluding Statement In conclusion, we wish to make certain that the Board has not been left with the impression that Union Carbide is opposed to monitoring and medical surveillance. Union Carbide strongly supports the need for both of these acti vities where significant asbestos exposures occur. Our plant employees have been provided with regular medical examinations since the plant opened in 1963. Although it is admittedly controversial as to what exposure is "significant" we believe that the present California level of one fiber/cc TWA, or some level in that general vicinity, such as the 0.5 fiber/cc level adopted by the Board at the April 26, 1979 hearing, is reasonable and meets the California objective of a standard which is enforceable and makes a positive contribution to employee health. To lower this level to the extreme of 0.1 fiber/cc TWA will A 08 53 ) UCC 014011 -9- extend monitoring and medical examination requirements to about 20,000 brake shops and quite probably an even larger number of construction sites where exposures are generally low. The return, in terms of worker health, on the large new investment of time, money and people by both the employer and the state com pliance operation is very questionable and limited technical resources are diverted from more urgent higher risk situations. Vie urge you to retain your present well written standards for asbestos and not to make the proposed changes that would return them to an outdated Federal requirement. Thank you for the opportunity to express our concerns. /dal 8/27/79 UCC 014012 A April 9, 1976 Docket Officer Docket H-033 U.S. Department of Labor Room N - 3620 200 Constitution Avenue, N.W. Washington, DC 20210 SUBJECT: OCCUPATIONAL EXPOSURE TO ASBESTOS *5r> Gentlemen: Reference is made to the proposed rules on this subject published in the Federal Register V. 40, No. 197, PG. 47652, which states that interested persons are invited to comment on or before December 8, 1975 which comment period was subsequently extended to April 9, 1976. Union Carbide is involved in the mining, milling and marketing of asbestos and we believe that the proposed rules will have a significant negative impact on our business. The attached presentation documents our position on the proposed revisions to the Occupational Standard on Airborne Asbestos. Our recommendations focus on the issue of insuring that the small or intermittent user of asbestos fiber is able to provide a safe work place for his employees without being unduly burdened by administrative or monitoring procedures. This presentation submitted this date also incorporates by reference the position expressed in the presentation by the Asbestos Information Associa tion/North America to the Occupational Safety and Health Administration, United States Department of Labor entitled: Notice of Proposed Rulemaking Occupational Exposure to Asbestos 29 CFR Part 1910 Federal Register, Vol. 40, No. 197, October 9, 1975 Asbestos Industry Response. 9 April, 1975 in which the name of Union Carbide Corporation appears as an endorser. We reserve the right to provide additional comments at any public hearing which may be scheduled relative to this rulemaking. Very truly yours, WCT:dal bcc: Messrs. 'h/ C. t (H U-) W. C. Thurber Business Manager-Asbestos G. G. Gabrielson, Jr. - AIA/NA Task Force Chairman J. J. Kenney R.F.X.Fusaro D. M. Mintzes Dr. H. B. Rhodes'' *7 U M/-, * ^ ^ r- o A T l\ / M A AOS 5 3 3 UCC 014013 PRESENTATION TO THE OCCUPATIONAL SAFETY AND HEALTH ADMINSITRATION UNITED STATES DEPARTMENT OF LABOR IN REGARD TO THE NOTICE OF PROPOSED RULEMAKING OCCUPATIONAL EXPOSURE TO ASBESTOS 29 CFR Part 1910 Federal Register, Vol. 40, No. 197, October 9, 1975 On behalf of UNION CARBIDE CORPORATION Date Submitted April 9, 1976 UCC 014014 A08534 -1- INTRODUCTION Union Carbide Corporation has been actively engaged since 1962 in the mining and milling of asbestos ore at facilities in central California. This asbestos is marketed throughout the United States and in many foreign countries. Union Carbide is a substantial supplier of short-fiber asbestos, similar to Canadian Grade 7, for the manufacture of floor tile, for tape joint compounds used in drywall finishing, and for oil-well drilling muds. We also supply highly refined asbestos fiber to about three hundred manufacturers of caulks, sealants, coatings, adhesives, mastics and similar materials that are widely used in the construction and automotive industries. We do not supply the longer fiber asbestos used for cement, fireproofing, or insulation products nor do we manufacture any asbestos-containing products. The great majority of our customers are small businessmen in the secondary and consumer asbestos industries who have limited technical capa bilities and resources. We are greatly concerned with the impact of the Proposed Rulemaking on these moderate sized but numerous users of asbestos. OSHA has recognized that this is a serious problem by the exclusion of the Construction Industry from the Proposed Rulemaking and the request for sug gestions for appropriate provision for other industries with similar problems as contained on page 47657 in the Preamble to this rulemaking; vis.: "While the proposal does not address itself to specific alternatives, OSHA invites comments concerning options which would both provide full protection to affected employees and at the same time would minimize the admin istrative and economic burden on affected employers especially those with small numbers of employees, non-fixed work places, or highly transient work forces." The main purpose of this presentation is to discuss the specific alternatives requested. Certain portions of the Proposed Rulemaking which we feel are inconsistent with the mandate given to OSHA in the Occupational Safety and Health Act (hereinafter referred to as the Act) are also discussed. The Proposed Rulemaking as well as the Asbestos Standard promulgated in 1972 are written to be applicable to conditions which normally occur in large, fixed places of employment, i.e..stable work forces who handle asbestos or asbestos-containing products for a major portion of most workdays throughout their working life. The application of such regulations to conditions where there is significantly less exposure is unnecessary and inequitable. It appears to be well within the scope of the Act to make allowances for this condition. The Act also makes a clear distinction between monitoring, medical surveillance and the attendant recordkeeping requirements that are intended to protect today's worker and those which are intended for research. Unfor tunately, the Proposed Rulemaking does not reflect this distinction and con sequently the entire industry would be required to operate as a closelycontrolled epidemiological research experiment. This will result in a tremen dous expenditure of scarce industrial hygiene and medical resources as well as money to amass vast amounts of information of which only a miniscule fraction will ever be used. It is this portion of the Proposed Rulemaking UCC 014015 AB53h -2- which is extremely burdensome to the large asbestos users, that becomes over whelming when applied to the smaller and infrequent users. Union Carbide believes that the Proposed Rulemaking should be modi fied to recognize the large gradation in exposure and the corresponding large gradation in hazard that exists in the working population to be covered. Research requirements should be defined and treated in a specific way, not imposed broadside on the entire industry. If this is done, the main diffi culties for most employers with small numbers of employees, non~fixed work places, or highly transient work forces that are noted by OSHA would be solved in a realistic and equitable fashion without decreasing worker protection or imposing large, unnecessary costs on the employer. It also seems inappropriate that OSHA should proceed with new rulemaking without making specific provisions for the serious problems of small businesses, non-fixed work places, or highly transient work forces that are known to exist in the present standard. GENERAL COMMENTS - PROPOSED RULEMAKING It was suggested in the previous section that the Proposed Rulemaking should be modified to allow for differences in the overall level of exposure experienced by different workers during their working lifetimes. This sug gestion is in accord with the provisions in paragraphs 6104 and 6114 of the Act. Section 3, Definitions, paragraph 6104 states: "(8) The term ''occupational safety and health standard" means a standard which requires conditions, or the adop tion and use of one or more practices, means, methods operations or processes, reasonably, necessary, or appro priate to provide safe or healthful employment and places of employment." (Emphasis added.) Section 6, paragraph 6114, Criteria for Standards, states: "(5) The Secretary, in promulgating standards dealing with toxic materials or harmful physical agents under this subsection, shall set the standard which most ade quately assures, to the extent feasible, on the basis of the best available evidence, that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working 1ife." (Emphasis added.) The key words here are "... reasonably necessary and appropriate" and "... regular exposure... for the period of his working life." A standard which is reasonably necessary for a worker who has regular exposure for the period of his working life is not reasonably necessary and may not be feasible for work situations of irregular exposure for periods considerably less than a working life. It is certainly appropriate to recognize this difference in the health standard. UCC 014015a i. -3- It was also suggested in the previous section that the Proposed Rulemaking does not make any distinction between monitoring, medical exam inations, and the attendant recordkeeping requirements needed to protect the worker and enforce the Act and those that are mainly for research purposes. The basis that such a distinction should be made is found in Sections 6, 8 and 20 of the Act. With regard to monitoring. Section 6, Labels, Warnings-Protective Equipment, states in paragraph 6116: "(7) ... Where appropriate, such standard... shall provide for monitoring or measuring employee exposure at such lo cations and intervals, and in such manner as may be neces sary for the protection of employees." (Emphasis added.) Section 20, Research and Related Activitiesstates in paragraph 6190: "(5) The Secretary... in order to develop needed infor mation___ may prescribe regulations requiring employers to measure, record, and make reports on the exposure of employees(Emphasis added.) "Upon the request of any employer who is required to measure and record exposure of employees... as provided under this subsection... the Secretary... shall furnish full financial or other assistance.for the purpose af defraying any additional expense incurred by him in carrying out the measuring and recording as provided in this section." (Emphasis added.) With regard to medical examinations, Section 6, paragraph 6116 states: "... where appropriate, any such standard shall prescribe the type and frequency of medical examinations and other tests... in order to most effect!vely determine whether the health of such employees is adversely affected by such exposure. In the event such medical examinations are in the nature of research... such examinations may be furnished at the expense of the Secretary of Health, Education: and Welfare." (Emphasis added.) Section 20, Research and Related Activities, states in paragraph 6190: "The Secretary... also is authorized to establish such programs of medical examinations and tests as may be necessary for determining the incidence of occupational illnesses and the susceptibility of employees to such illnesses." With regard to recordkeeping. Section 8,- in paragraph 6128, Accident and Illness Records, states: A0850 UCC 014016 -4- "(C) (1) Each employer shall make, keep and preserve ... such records regarding his activities relating to this Act as the Secretary___ may prescribe.... as necessary or appropriate for the enforcement of the Act or for developing of information regarding the causes and prevention of occupational accidents and illnesses." (Emphasis added.) It has already been noted that Section 20 provides for financial assistance for monitoring records obtained and retained for research purposes. Finally, the extent of recordkeeping which can be required by the Secretary is clearly limited by Section 8, paragraph 6130, which states: "(d) Any information obtained by the Secretary----under this Act, shall be obtained with a minimum burden upon employers especially those operating small businesses. Unnecessary duplication of efforts in obtaining information shall be reduced to the maximum extent feasible." (Emphasis added.) The key point to note in these quotations is that Congress, in writ ing the Act, made a clear and repeated distinction between monitoring, medical examinations and recordkeeping that were intended to protect the employee and those which constituted research. One.of.the major shortcomings of the Proposed Rulemaking is the failure to incorporate this distinction into the regulations. Every employer, large and small, is required to prepare the same very detailed records and store them for 40 years or more. The Preamble to the Proposed Rulemaking discusses the concept of the "technical feasibility" of the suggested new rules but does not clarify what is meant by this term. In fact, the crucial words "to the extent feasible" are omitted when the relevant section of the Act is quoted on page 47053, Column 3 in the Preamble. In view of the extremely low allowable exposure levels proposed by OSKA and the possible differences in what is feasible in various occupational situations, it is particularly important to establish the meaning of these words in the context of the Act. The phrase, "... to the extent feasible" was an amendment to the Act offered by Senator davits. The Senator explained the rationale of the amend-? ment as follows: A08538 "As a result of this amendment, the Secretary, in setting standards, is expressly required to consider feasibility of proposed standards. This is an improve ment over the Daniels Bill, which might be interpreted to require absolute health and safety in all cases, regardless of feasibility, and the administration bill, which contains no criteria for standards at all." S. Rep. No. 91-1282, 91st Cong., 2d Sess., at p. 58; legis. Hist, at p. 97. In Industrial Union Department, AFL-CIO, et. al, vs - Hodgson, 499 F. 2d 467, (C.A.D.C., 1974) (Appeal on First Asbestos Standard) the Court concluded that economic factors as well as technological factors are integral components in the concept and determination of feasibility. UCC 014016a -5- The Court states at p. 477 in this decision: "There can be.no question that OSHA represented a decision to require safeguards for the health of employees even if such measures substantially in crease production costs. This is not, however, the same thing as saying that Congress intended to re quire immediate implementation of all protective measures technologically achieveable without regard to their economic impact." (Emphasis added.) and at p. 478: "Congress does not appear to have intended to protect employees by putting their employers out of business-either by requiring protective devices unavailable under existing technology or by making financial liability generally impossible." (Emphasis added.) ` It is evident from these passages that the basic objective of the Act is to protect the health and safety of the worker to the extent that is technologically and economically feasible. This distinction becomes parti cularly relevant when the medical examination and recordkeeping provisions of the Proposed Rulemaking are applied to small businesses, transient work places, and transient work forces. SPECIFIC COMMENTS - PROPOSED RULEMAKING Sections 1910.1001 (a) Scope and Application and (e) (1) Monitoring. Initial With the exception of the construction industry, which will be covered separately, the Scope and Application section is virtually universal. It not only covers products where commercial asbestos is deliberately intro duced but also where even minute quantities are present as impurities in any of the raw materials. This is expanded greatly by the inclusion of tremolite, a frequent impurity in talcs, in the definition of asbestos without any dis tinction between the asbestiform and non-asbestiform varieties of this mineral. Finally, the use of the word "stored1' brings under the regulation every place where a product containing asbestos is present whether or not it is even re moved from the package. This universal definition of Scope and Application is combined in the Proposed Rulemaking with paragraph (e) Monitoring, which requires an initial monitoring at. "... every place of employment where asbestos fibers may be released". At least a second monitoring, must also be made regardless of the initial results. This differs substantially from the present regula tions where the initial monitoring is needed only at places where asbestos fibers are released and in many situations further monitoring is not required. A 08 5 3 9 UCC 014017 -6- It has been estimated^that there are approximately 258,000 places of employment in the secondary asbestos industries and 140,000 places in the asbestos consumer industries. Under a literal interpretation of the proposed regulation, it could be construed that fibers "may be released" at all of these locations. This is so, even though by the very nature of these opera tions a substantial portion are already in compliance with the proposed 0.5 fiber TWA standard. A monitoring requirement of staggering proportions results. At the present time there are 90 laboratories participating in the NI0SH PAT Program to demonstrate competence to count airborne asbestos fibers. Approximately 70 of these are large company laboratories or are operated by states for compliance purposes and are not available for outside counting. A dust count by a consulting laboratory costs about $400. At this rate it would cost $320,000,000 to provide the 800,000 surveys that would be mandated by the Proposed Rulemaking. Due to geographical limitations and the need to collect sufficient samples to calculate an 8-hour time-weighted average it is estimated that each of the 20 laboratories could sample about two locations per day. At this rate it would take about 80 years to carry out this initial screening. It is recognized that some laboratories can handle more than two locations per day and more people are entering the field, but it must also be remembered that asbestos is only one of about 400 substances to be regulated. The same pool of trained personnel will be needed to provide similar services for these other materials. It is clearly impossible for industry to comply with this provision of the proposed standard. We feel that this sweeping monitoring program mandated without regard to the potential hazard that actually exists at the places to be mon itored is not "... reasonably necessary or appropriate to provide safe or healthful employment and places of employment." In addition, it is not "... necessary or appropriate for the enforcement of the Act or for the develop ment of information..." or for research. It is a grossly unreasonable fin ancial burden on the employer and a poor and inefficient use of limited indus trial hygiene resources. As such it detracts from rather than adds to the protection of the workers. Finally, the words "may be released" without any qualification as to quantity, frequency or even probability that such an event will actually occur are too vague to be enforceable and are inappropriate in a regulation of this sort. It would also appear that they do not meet the requirements of the Criteria for Standards expressed in paragraph 6114 of the Act: "Whenever practicable, the standard promulgated shall be expressed in terms of objective criteria and of the performance desired." It is suggested that the difficulties can be corrected within the provisions of the Act if an initial assessment of the hazard potential based on available information is required. Where suitable information for a rea sonably reliable assessment is lacking it would need to be obtained. Monitor ing would only be required where such an assessment could not be made or where there was a reasonable possibility that either of the allowable limits would be exceeded. Such an approach is well accepted industrial hygiene practice. (1)technological Feasibility and Economic Impact of OSHA Proposed Revision to tjhe Asbestos Standard. Prepared by Roy H. Weston, Inc., March 29, 1976, UCC 014017a 40e 5 -7- As an alternative, the exception for bound fibers now used in the Proposed Rulemaking in connection with Danger Labels, paragraph (1) (2) could also be applied to monitoring. A suitable wording would be: "Monitoring is not required for asbestos or asbestos containing products.where asbestos fibers have been modified by a bonding- agent, coating, binder, or other material so that during: any reasonably forseeable use, handling* storage, disposal,, processing, or transpor- ' tation no airborne concentrations in excess of either of the limits specified irr paragraph (c) of this sectionare released." This second wording has an advantage that this type of provision was adopted by the Construction Industry OSHA Advisory Committee at their meeting on September 17-18, 19.75. It would remove one of the major problems in the application of the Proposed Rulemaking to the construction industry and the other problem areas that are the subject of this discussion. Paragraph (c) Permissible Exposure to Airborne Concentrations of Asbestos Fibers In arriving at the proposed 0.5 fiber/cc standard, OSHA has stated in the Preamble to the Proposed Rulemakings "OSHA recognizes that there is no assurance of a safe exposure for a substance with known carcino genic property, in this case asbestos, and thus there should be no detectable concentrations." And: "While some level, below which exposure to a car cinogen does not cause cancer, may conceivably exist for any one individual, other individuals in the working population may have cancer induced by doses so low as to be effectively zero." In taking this position OSHA has embraced the new "one-hit" hypothesis that is speculative and unproven. We feel that at this time, this theory does not meet the "... on the best available evidence..." requirement stated in paragraph 6114 of the Act. It is also questioned whether it is suitable under the "... with respect to questions of fact, if supported by substantial evi dence on the record considered as a whole, shall be conclusive..." provisions of paragraph 6142, Judicial Review. A0854 1 Paragraph (d), Regulated Areas This paragraph introduces a new concept to the asbestos regulations wherein "any work area where a person may be exposed to airborne concentrations of asbestos fibers in excess of either of'the limits shalT be designated as a regulated area." The existence of such an area in a plant triggers very substantial additional compliance obligations of prohibited entrance by other UCC 014018 - 8- - persons, warning signs, rosters, change rooms, lavatories, hygiene programs, prohibited activities in such areas and an employee training program. In many cases compliance can only be achieved by extensive relocation of equipment. The basic concept of the regulated area is certainly a means to limit exposure to as few people as practicable but the use of the ''may be exposed*' wording is so vague that almost any place where unbound asbestos fiber is used can be construed to be a regulated area. We feel that regulated areas should be clearly defined as places where there is actual regular exposure of levels over the allowable limit. The speculative phrase, "may be exposed" is too vague to be enforceable and is inappropriate language for a regulation. This change would reduce the number of regulated areas to those places where a hazard exists and greatly reduce the burden for all industry and particularly those for the occasional or short term user and for non-fixed work places. Paragraph (d) also provides for a daily roster of all persons entering a regulated area. This is clearly an attempt to obtain very detailed work history records for research. The corresponding exposure data would only be measured once a month, would not match the roster in'detail, and would thus negate the value of such a roster. The same information, to the degree of detail that could possibly be needed for research, can easily be obtained from employee assignment records. The roster requirement is thus in conflict with paragraph 6130, Obtaining Information, in the Act which requires that information be obtained with a minimum burden upon employers. This portion of paragraph (d) should be deleted. Paragraph (f), Methods of Compliance The Proposed Rulemaking requires that engineering controls be installed, "except to the extent that such controls are not feasible", whether or not such controls will' reduce exposure to allowable levels. Work practice controls must be used to supplement engineering controls where needed and, finally, respirators are permitted as a last means of compliance. Engineering controls and work practices both protect the employee by reducing his exposure. Neither method is absolutely reliable and both are subject to mechanical and human failure. Vie feel that making engineering controls pre-eminent exceeds the "reasonably necessary or appropriate" pro vision of paragraph 6104, Section (3) subpart 8 of the Act and that engineer ing controls and work practices should be equally acceptable procedures to achieve compliance. In addition, Union Carbide takes strong exception to the apparent attempt to place the burden of disproving the existence of feasible engineering controls on the employer. The burden of proof has been shifted from the regulator to the regulated whereby the latter would, in effect be required to prove a negative to establish his innocence. This is contrary to the intent of the Act and repugnant to basic regulatory principles and the tradition of due process. As noted previously. Section 6, paragraph 6114 of the Act, Criteria r for Standards includes the words: ^ "... even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working 1 ife.11 (Emphasis added.) Co O UCC 014018a -9- It is certainly appropriate that OSHA provide a standard which meets these criteria for protection of the employee with regular exposure for the period of his working life. In view of the "to the extent feasible" wording in this same paragraph and the subsequent court ruling, IUD, AFL-CIQ vs. Hodgson, on this subject that was discussed previously, it is questioned whether it is "reasonably necessary or appropriate" to apply this same standard to employees with irregular exposures or who are regularly exposed for only a moderate frac tion of their working life. This problem is exemplified by a worker who, although at a fixed place of employment, dumps a few bags of asbestos into a process vessel once a day. This situation is widespread, for example, in the great multiplicity of small businesses where adhesive and specialty coatings are manufactured as a small part of a broader line of products. In many cases engineering controls that would only be used intermittently for short periods would impose a pro hibitive financial burden. We feel that it is appropriate and within the scope of the Act to permit the use of respirators with suitable limitations on the time they may be worn in any shift, as the primary means of compliance when asbestos is used only intermittently or occasionally. This would also facilitate compliance in many norr-fixed work places, or small businesses which would have great difficulty in complying with the proposed regulations. Paragraph (g) (3) (iv) The Proposed Rulemaking moves further than the present standard in it's requirements for the transfer to other employment of any employee who is found to be unsuitable to wear a respirator. Further, in the Preamble, page 47658, OSHA states: "If warranted, OSHA may consider job reassignment based on medical unsuitability, per se, as the subject for a separate rulemaking procedure." There: is no authority in the Act for OSHA to include this subject in any regulation promulgated thereunder. It is a complex subject impinging on labor relations, workmen's compensation, and other existing legislation. It is suggested that this is a more fitting subject for collective bargaining. Paragraph (i). Hygiene Facilities and Practices Subsection (4) of this paragraph states: "Clothes lockers and shower facilities shall be arranged so as to separate regulated areas and uncontaminated areas." (Emphasis added.)~ Subsection (5) states: "Lavatory and toilet facilities which are located in regulated areas shall be arranged so: that no access is available from them- to uncontaminatecf areas." (Emphasis added.) AO8543 UCC 014019 -10- The meaning of these provisions is not entirely clear but it would appear that OSHA envisions that each regulated area will be segregated physi cally by a fence or other means and that the only entrance and exit will be through shower and change rooms. There is no provision for raw materials to enter or products to leave except through the shower and change room. If this is OSHA's intent it clearly exceeds the "reasonably necessary or appropriate" criteria for standards and when applied to small businesses and non-fixed places of employment is generally not feasible. Locker rooms and shower facilities are already subject to the allowable levels prescribed in the reg ulations and regulated areas are set off by warning signs. These additional provisions are confusing, unnecessary, and unworkable, and should be deleted. This section of the Proposed Rulemaking also states that: "... employees----- shall be required to shower before leaving at the end of the work shift." And: "Employees... shall be required to wash hands, face, and forearms prior to eating, drinking, or smoking." There is no question that these are very desirable personal hygiene procedures but to make it a citable offense for the employer if the employee refuses to follow them is unreasonable. The employer can only provide the facilities, educate the employee on the need and desirability to use them, and encourage him to do so. Actually, the Act is quite clear on the responsibility in this case. Paragraph 6103, Enumerated Purpose, states: "(2) By providing that employers and employees have separate but dependent responsibilities and rights with respect to achieving safe and healthful working conditions;" This point, is emphasized in the general duty provisions of Section 5 (b) which states: "(b) Each employee shall comply with occupational safety and health standards ana all rules, regulations, and orders issued pursuant to this Act which are appli cable to his own actions and conduct." (Emphasis added.) We feel that OSHA has exceeded the mandate granted in the Act by proposing to make employers responsible for the personal hygiene of their employees and has failed to comply with a clear-cut intent in the Act by not making each employee directly responsible for compliance with rules applicable to his own conduct. Paragraph (j), Medical Surveillance and (n) Recordkeeping The present asbestos regulations require an annual medical examination for every employee in any occupation exposed to "airborne concentrations of asbestos fibers." A recent review commission decision found that this was not UCC 014019a fl8 5 4 4 -11- 4 limited to exposure levels over the allowable limits but to any level whatsoever. The Proposed Rulemaking continues this provision and increases the time that the employer must store the medical records. It is also proposed that monitoring records be kept for the same extensive period of 40 years or more. It is in these provisions that OSHA has failed to distinguish properly between employee protection and research. As a result, the proposed regulations place an extreme and unnecessary burden on all employers and an even greater and more unnecessary burden on employers whose employees are not regularly exposed for the period of their working lives. The Weston study cited previously estimates that about 15 million workers will be required to have annual medical examinations under the Proposed Rulemaking. This does not include an estimated 3-5 million additional workers engaged in the construction and shipyard industries. It also obviously does not include-workers covered by similar OSHA standards now in effect or being promulgated under the standards completion programs who would be obtaining examinations from the same "poolrt of medical practitioners. At the present time there are approximately 350,000 licensed physicians in the United States. Estimates of the number who have a registered specialty in industrial medicine or have acquired special knowledge in this area as a result of their particular practices vary from 2000-5000. For 5000 physicians to give 20,000,000 examinations annually in accordance with the Proposed Rulemaking would require an average of 4000 examinations per year per physician, an obvious impossibility. To use this limited resource most effi ciently medical examinations should be required only for those workers exposed to levels over the allowable limits. It is well documented in medical research that there is typically a 20 year latent period before the appearance of asbestos.related disease and that this period generally increases as the exposure level goes down. On this basis, annual examinations for at least the first 10 years of exposure do not contribute to the-protection of the worker or provide research information. A tremendous decrease can be made in the medical examination burden without de tracting from worker protection by reducing the examination period to once every 5 years for the first TO years of employment. This would also make the regu lation more reasonable for transient work force conditions and reduce the recordkeeping load. , It is clear from the Act that OSHA has a research responsibility to fulfill. The Proposed Rulemaking does this by adding to the universal medical examination requirements, universal provisions for keeping all of the medical and the corresponding monitoring records for 40 years or more. Successors to the business must keep such records and only in the case of a complete shut down can the records be sent to the Secretary. We question the need for a 100? cohort of about 20,000,000 workers to obtain valid epidemiological conclusions. What is the real possibility that any future study will examine the hfstory of more than a very small frac tion af this overwhelming mass of data? This is especially true if the reg ulations which have been adopted result in the elimination of asbestos related disease as expected. The motivation and funds to analyze these data will neither be available nor required. Union Carbide believes that the require ments that such records be kept 40 years or more by all employers is not "necessary or appropriate" for the ^r^tection of the worker and grossly UCC 014020 -12- exceeds any reasonable requirements for "determining the incidence of occu pational illnesses." It is also in conflict with the "minimum burden" pro visions of the Act. Instead of this impractical, cumbersome, and grossly excessive approach it is suggested that the research requirements of the Act can most effectively be met if OSHA will set up a planned research protocol with realistically sized cohorts for the range of exposure conditions to be studied. The workers covered would be designated and their records sent to OSHA at 5 year intervals. This would remove the necessity for long term storage of millions of records and employers would be permitted to discard such records after a 5 year period. SUMMARY Union Carbide believes that the Proposed Rulemaking which has been written to protect workers who are regularly exposed to the asbestos hazard for their entire working lifetime, is excessively burdensome and is not "rea sonably necessary or appropriate" for the majority of workers who have a lesser degree of exposure. There is good basis in the Act to consider this gradation of exposure. Union Carbide also believes that the treatment of the entire industry as a large epidemiological experiment far exceeds the provisions of the Act for both worker protection and for research. The following suggestions are offered to make the regulations more appropriate both for large fixed places of employment and for the particular problems encountered by employers with small businesses, non-fixed work places, transient labor or intermittent exposure. 1. Limit medical examinations to those workers regularly exposed to levels over the allowable limits. Such examinations would be at 5 year intervals for employees with less than 10 year exposure. 2. Define realistically-sized cohorts of workers who's medical history will be followed extensively to -satisfy the research requirements of the Act. Records for these workers would be sent to the Secretary at 5 year intervals. Mandatory storage of records by employers would be limited to 5 years. 3. Narrow the definition of regulated areas to include only those places where the allowable levels are regularly exceeded. 4. Not require initial monitoring at those places where there is no reasonably foreseeable possibility that the allowable limits will be exceeded. 5. Make engineering controls and work practices co-equal methods to achieve compliance. Allow limited use of respirators as the pri mary means to achieve compliance for intermittent and short-term exposure conditions and for small businesses. 6. Delete the special requirements relative to the location and arrangement of change rooms and shower facilities and operate such facilities under the regular provisions of the Act. UCC 014020a *03548 ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD, NOVEMBER 8, 1978 Mr. Chairman, Members of the Standards Board. My name is Harrison Rhodes and I am employed by Union Carbide Corporation. The continued use of certain products wherein the asbestos fibers are wetted and encapsulated is extremely important to a large number of California manufacturers and users. They are represented here today by a number of experts who are prepared to answer any technical or business questionsyou may have. You have already received our written testimony and there is little point in reiterating it here today, although we can discuss it more thoroughly at your discretion. My intent is to show you some samples of the products so you can see what we are talking about. These samples show both the products in the form to be sprayed and the final product after cure. I will also summarize a spraying study which appears to be quite relevant and which came to my attention after the written testimony was prepared. A complete copy of this report was submitted to Mr. Rinaldi yesterday and may be in your folders. Let me emphasize that we are discussing only products where the asbestos fibers are wetted and encapsulated from manufacture through final usage. These include the coating and laminating materials and both types of fibrated roof coatings, that is those manufactured from cold-process cut back asphalt and those from emulsified asphalt. We are not addressing the Portland cement plaster or the naturally occurring impurity portions of the hearing. A08547 UCC 014021 -2- As a frame of reference, let us first look at the asbestos-containing spray insulation material of the type that was the principal target of the 1974 legislation (60% mineral wool, 25% asbestos, 15% Portland cement.) This is the material as it was delivered to the construction site and this is what it looks like after application. Notice that I can pull it off with my fingers and crumble it to a powder. To use the Federal EPA definition it is friable. Excessive dust generation would be expected during field mixing and during renovation or removal. There are no objections to the banning of these materials and any like them. In contrast to this extremely friable material, all of the products for which we are requesting exemption must perform a protective or structural function which is defeated if they become friable. The first examples are a polyester laminating resin containing about three-quarters of one percent asbestos and a maintenance coating with about 2.5%. The laminating resin is used in conjunction with fiberglass to build up strong, rot-resistant structures such as boats. This is an example of one layer of the cured product. It is normally built up in layers to a thickness of a quarter of an inch or more. This is the finished maintenance coating containing 2.5% by weight asbestos. It is also hard and definitely not friable. Next are two examples of roof coatings. This one has an emulsified asphalt base and this one uses cutback. They contain about 9 and 7 weight percent asbestos after cure, respectively. Note that the cured coating is slightly flexible or resilient. These products must be formulated this way to allow for the effects of temperature change. A set of roofing product samples containing a much wider range of asbestos contents has been prepared by the W. W. Henry Company and will be described subsequently by Mr. Paul Beemer, the General Manager of that company. A 08 5 48 UCC 014022 -3- The spraying test I mentioned earlier, which was not included in our written testimony, was conducted by a consulting firm for the H. B. Fuller Company. This study was submitted by H. B. Fuller as part of their testimony on a proposed Federal EPA regulation on the spraying of asbestos-containing materials. The materials sprayed consisted of a series of mastics used to provide weather-barrier coatings over soft thermal insulation on tanks, roofs, lines, etc. Asbestos contents were 1.8, 6.6, and 14.3% by weight chrysotile and a mixture of 13.7% chrysotile and 34.9% of Asbestine Fiber #2 talc. It is important to note that although Asbestine Fiber #2 is talc, not asbestos, it does contain a substantial portion of mineral particulate which would have been counted as asbestos by the consultant making this study if it became airborne. The mastics were sprayed under two sets of conditions; in a closed 20x20 foot room to approximate the worst possible case, although the products are not normally used indoors; and in an outdoor application. The airborne fiber counts found are presented in this figure in the same manner as the other data in Figure 1, page 10, in the testimony. The fiber concentration in fiber/cc longer than 5 microns is shown on the vertical axis. The present DOSHA allowable limits of 10 fiber/cc ceiling, 2 fibers/cc TWA and the 1 fiber/cc maximum TWA set by SB-1591 are shown for reference. The four mastics are arranged in order of increasing mineral content from 1.8 to 48.6% by weight after cure. A 08 54 9 The solid circles show the operator breathing zone concentration. These are all in the 0,1 -0.2 fiber/cc range. The bars show the maximum or ceiling values, the range, and the arithmetic mean for the area samples in the immediate vicinity of the spraying operation. The highest value found was about 0.5 fiber/cc for the non-typical interior spraying of the Hi Mastic. The remaining values were in the zero to 0.2 fiber/cc range. As an added UCC 014023 -4point of interest, the Gallo Company sprayed 40,000 gallons of the Monolar Mastic containing 6.6% asbestos to insulate the exterior surfaces of wine storage tanks located out-of-doors in Modesto. Air samples were collected on membrane filters. No airborne fibers were detected by microscopic examination. The important point to note in these data is that the airborne fiber concentrations are all very low with no clearly defined trends with mineral content in the material being sprayed up to a total mineral loading of 48.6% by weight after cure. This result is very similar to the spraying and product removal data given in Figure 1, page 10 of the written testimony, indicating quite conclusively that the airborne asbestos exposure does not change a measureable amount with the asbestos content as long as the fibers are thoroughly wetted arid encapsulated. For these products to be commercially useful, they must be wetted and encapsulated. To conclude, the products with which we are concerned perform a useful and valid service for industry and for the general public. They contain wetted and encapsulated fibers which do not expose workers to fiber levels in excess of those established by DOSHA or SB-1591. We would not be here today if we were not convinced that the products could be used safely and within the confines of existing regulations. We request that continued use of these products be permitted by your action to modify Section 5208, Title 8, as suggested in our written testimony including a maximum allowable TWA exposure of one fiber/cc >5y. Thank you very much for the opportunity to express these views. With your permission, Mr. Paul Beemer would like to present the additional samples mentioned earlier. &0855C UCC 014024 Union Carbide Corporation f Metals Division Niagara Falls, NY 14302 November 30, 1976 MEMO RANDOM To: J. L. Myers From: H. B. Rhodes Copies: R. E. Byrne, Jr. T. P. Norris R. L. Schult W. C. Thurber**"'^ File DEc & iy/6 Subject: Status of Denver ' Denver Drywall is the drywall contractor for the Johns-Manville World Headquarters in Denver. They were using a mud manufactured by a UCC customer, Drywall Supply, as the first coat in a three-coat finishing procedure. This mud contained about 1% SG-210. The mud used for the other two coats contained no asbestos. By a communications mix up, Denver Drywall was under the impres sion that the Drywall Supply mud also did not contain asbestos and had so certified to Turner Brothers, Inc. the prime contractor on the job. On July 15, 1976, the site was inspected by Colorado State OSHA in response to an employee dust complaint. Denver Drywall received asbestos related citations for lack of monitoring and lack of medical examinations. Turner Brothers received a citation^for lack of medical examinations. Following the citations, UCC collected and analyzed dust samples at the J/M site (where no asbestos was now being used) and at another site where the previous system, i.e. base coat only contained asbestos, were in use. Our results indicated that asbestos exposures were so low that it was unlikely that they could be proven to be different from background levels. Denver Drywall filed notice of opposition and an informal conference was scheduled. Denver Drywall pushed the position that OSHA had not adequately demonstrated exposure, and if there was exposure it had not come from their wet mud. OSHA which was obviously in a weak position offered as a compromise to remove all fines and accept the offer to the employees of one physical examina tion by Denver Drywall and 4-5 by Turner as meeting compliance. Mr. Mitchell, the president of Denver Drywall, was seeking our comments on the desirability of not accepting this compromise and going on to the review commission as a matter of principle and to help with the overall battle with OSHA. The UCC involvement would be, at the least, the provision of expert testi mony on monitoring results and procedures. I told Mr. Mitchell that I felt that the technical merits of his position were solid but that this did not look to me like a good place to do battle on the monitoring reliability question. The strong appreciation of both UCC and the AIA/NA for his willingness to help was expressed. UCC 014025 j\ 0 8 5 5 1 i * Memo: J. L. Myers 2- - November 30, 1976 At the present time Mr. Mitchell is extremely annoyed at Drywall Supply for misleading him and is not using any asbestos-containing muds. If a realistic set of construction regulations can be obtained from the current negotiations with OSHA he is a likely cqndidate to go back to such muds. He is one of the largest drywall contractors in the Rocky Mountain area and is quite influential in the national affairs of the contractors association. H. B. Rhodes HBR:dal UCC 014026 BOO