Document KGd6eNjOaqEZOVBbamQ6Xgqvw
CELANESE CHEMICAL COMPANY Chemcel Plant Bishop, Texas
TO: Mr. E. Munoz
FROM: G. 11le
GI-83
January 3, 1980
ASBESTOS PERSONAL EXPOSURE DATA REVIEW AND RECOMMENDATIONS
A review of asbestos personal sampling data, collected from as early as July 1976 to the present, is summarized below. The primary objective of this review is to evaluate employee exposure to asbestos and to suggest two additions to the draft asbestos administrative procedure (AP) to better define enforcement responsibilities and reporting of spills. Table 1 summarizes the peak exposure concentrations collected on production employees during the actual blend operation and the calculated time-weighted average (TWA) concentrations for an 8-hour day, assuming negligible asbestos exposure during periods when no blend is made. The peak exposure data may be compared to the OSHA ceiling level of 10 fibers per cubic centimeter (fibers/cc), while the 8-hour TWA concentration is compared to the 2 fibers/cc level. A statistical review of the data indicates that there is a 5% probability of exceeding a 0.3 fibers/cc, TWA asbestos concentration in Celanex, a 5% probability of exceeding a 0.04 fibers/cc TWA asbestos concentration in Special Products and a 5% probability of exceeding, respectively, a 2.3 and 1.2 fibers/cc peak concentration levels in Celanex and Special Products. These data indicate that our handling procedures for asbestos is effective, that long term exposure is minimal and that the probability of a long-term health hazard is small.
Standards for exposure to asbestos fibers have continued to be reduced as more information has been made available through research and epidemiological studies. In 1970, OSHA recommended 12 fibers/cc, TWA which was reduced to five fibers/cc in 1971 under an OSHA Temporary Emergency Standard. In 1972, a Permanent Emergency Standard went into effect maintaining the standard at 3 fibers/cc with an automatic reduction to 2 fibers/cc in 1976. This standard, with a 10 fiber/cc ceiling exposure limit remains in effect today. On October 9, 1975, OSHA proposed a new regulation for asbestos, effectively lowering the TWA exposure limit to 0.5 fibers/cc and the ceiling exposure limit to 5 fibers/cc. This proposed standard was rejected by the asbestos industry as "unnecessary, impractical and lacks medical justification^:." In December of 1976, the National Institute for Occupational
Safety and Health (NI0SH), a research organization under the Health, Education and Welfare Department, recommended to OSHA a 0.1 fiber/cc TWA exposure limit and a 0.5 fiber ceiling limit, primarily to protect against lung cancer and mesothelioma. This recommendation was based on the fact that no "safe" level of asbestos exposure could be found and that any exposure level should be based on the lowest detectable limit. The American Council of Governmental Industrial Hygienists (ACGIH), has recommended 2 fibers/cc as an 8-hour TWA exposure level for chrysotile asbestos fibers. In general, the standards published by this professional group are more stringent than those of OSHA and are regarded to more realistically protect the health of the worker in industry.
At this time, the answer as to how much asbestos exposure is hazardous is still uncertain. Both asbestosis, a progressive deterioration of lung function, and lung cancer are thought to be dose related. This implies that an asbestos dose or concentration should exist, below which impairment or injury does not occur.
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Mesothelioma, a rare cancer of the chest and abdominal cavity lining, has also been found to occur more frequently in people with exposure to asbestos. Although not enough information' is presently available to fully ascertain the risk associated with exposure to asbestos, I believe that our employee exposure history for production employees is minimal and that with some additional administrative controls to monitor exposure during opening of and entrance into the SEO Dust Collection Systems, no long-term chronic health effects should occur. This conclusion is based on our present handling procedures for asbestos, the engineering controls that exist to minimize exposure to fibrous asbestos materials, and the low exposure data that has been collected so far. In addition, a compre hensive study conducted by the British Occupational Hygiene Society between 1933 and 1966 concluded that "for an accumulated exposure of 100 fibre-years/cc, it is probable that the risk of being affected, to the extent of having the earliest clinically demonstrated signs, is less than 1%T." This important concept, of relating prevalence of disease with concentration and duration of exposure, suggests that employees can safely work in asbestos environments of 2 fibers/cc for 50 years, A fibres/cc for 25 years, orlO fibers/cc for 10 years without developing (992 confidence) the earliest clinical signs of asbestosis. It should again be noted that it is still controversial as to whether the 2 fiber/cc concen tration level adequately protects employees against lung cancer or mesothelioma.
Two recommendations were made to further strengthen the asbestos AP and insure that the main goal of protecting employees is achieved. These include a section under enforcement responsibilities and reporting requirements during asbestos spills. With your concurrence, they will be placed under section AS and A6 of the Administrative Procedure in the following format:
1. Enforcement Responsibility
The responsibility for assuring that the above requirements are fullfilled shall lie with the owning shift supervisor, safety department, and the employee's immediate supervisor. The owning shift supervisor shall be responsible for noting on the AVO whether an asbestos entry or general maintenance permit is required. He will assure that the equipment to be worked on is down and`ready for maintenance. The following permits and the protective equipment required for each is listed below:
(a) Entry Permit - When entry is to be made into any vessel or confined space of the SEO Blend System, the following safety equipment shall Be worn:
(1) Positive pressure, airline respirator,
(2) Disposable coverall, including shoe covers and suitable head covering.
(b) General Maintenance Permit - When any portion of the SEO Dust Collection System/Product Conveying System is opened for either maintenance or inspection, the following safety equipment shall be worn:
(1) Approved disposable filter respirator.
(2) Disposable coveralls.
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The General Maintenance Permit shall be issued by the owning shift supervisor who will be responsible for insuring that the above protective equipment is worn.
2. Reporting of Asbestos Spills
All incidences involving the release of asbestos raw materils (e.g. broken asbestos bags, blown out or leaking rubber connectors, etc.) shall be reported to Management, with a copy to the Industrial Hygienist and the Environmental Health Chemist, on the form provided. This will insure adequate historical exposure documentation for the Health Surveillance System.
It should be noted that both the Environmental Protection Agency and the Consumer Product Safety Commission have published advanced notices proposing to eliminate all non-essential uses of asbestos. This is primarily based on studies that show that asbestosis and various cancers are "associated with asbestos exposure, even at low concentrations or after short exposure periods^". An . attachment is included for your review. In addition, a Celanex asbestos study was performed by L. R. Birkner and S. Z. Lu to evaluate customer exposure to air borne asbestos fibers during molding, grinding, sanding, and general handling of Celanex VO product. They concluded in the study that customer exposure to asbestos fibers was significantly below current and proposed health standards.
Finally, the asbestos sampling data summarized in Table 1 does not represent operator and helper actual exposure because disposable respirators are worn during the entire SEO Blend operation. Also, the counting method used by the National Loss Control Laboratory, a certified Industrial Hygiene Laboratory, counts fibers and does not differentiate between asbestos or any other fiber, such as glass. Any comments regarding the changes to the Draft Asbestos AP outlined above should be made by January 11, 1980.
GI:el
G. Ille
References
1 Rajhans, G. S., "Here's an Update on Asbestos," Occupational Health and Safety, December, 1977.
2 Chemical Regulation Reporter, "EPA Advance Notice of Proposed Rulemaking on Commercial and Industrial Use of Asbestos," October 19, 1979, pp 1175-1181.
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FIVE PERCENT PROBABILITY OF EXCEEDING LISTED ASBESTOS PEAK
8 -AND HOUR CALCULATED TWA EXPOSURE CONCENTRATIONS BY UNIT
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SPILL OR EXPOSURE MONITORING REPORT TO: Technical Manager
Unit Superintendent Unit Supervisor Environmental Coordinator Industrial Hygienist Environmental Health Chemist DATE:_______________________________________ UNIT AFFECTED:___________________________ EQUIPMENT AFFECTED:_____________________ CHEMICAL(S) INVOLVED:__________________
ESTIMATED LOSS:_______________ DURATION OF SPILL/EXPOSURE:
EMPLOYEES INVOLVED:
ESTIMATED AIRBORNE CONCENTRATION:
EXPLANATION FOR THE SPILL:
SUGGESTIONS FOR PREVENTING SIMILAR OCCURRENCE:
COMMENTS:
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CURR ENT REPORT^ n ji ;; q
1155
.Terrell:E. Hunt, .chief of-the EPA Toxic. Substances Branch in the Office of Enforcement, Washington, D.C., said four factors explain the spate of PCB.enforcement actions. .. One major, factor is that the .PCB rule is. a ."relatively mature.enforcement program" with remedies that can-be applied quickly.and,effectively,-Hunt said.vis:
J`EPA's ability tcPissuecivIl complaints and seek court iiv
junctions for alleged violations of the PCB rule makes its use
increasingly popular among agency enforcement personnel.
Hunt. said. yim rc.iri.'TiiTTrc; rJJ
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-In addition, cleanup of. PCB violations often produces
cleanup, of other hazardous substances and poor storage
conditions as well, he said. .
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(cAnd,- because.:PCBs_are^so.,widespread ;and frequently
found mixed with other toxic..materials, ordering'the clean
up of the PCBs generally produces other cleanup activities
at sites where the.PCB violations occur, be. said.-t*;.'
r. Hunt ackowledged that recent publicity surrounding PCBs
in food have had a positive effect on enforcement actions by
making both industry and agency personnel more aware of
the hazard of PCBs.,^^-j
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Some of the actions, however, have been pending for quite
some, time and are. being filed at the same time only by
chance. Hunt said..".,-
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,-He did say, however,; .that. EPA headquarters in
Washington recently, surveyed the .enforcement goals outlined
by^regional officials at the beginning of fiscal 1979.
Many of tbe regions were reminded that they were falling
short of their inspection goals, Hunt said. The reminder from
headquarters spurred, many of the regions to increase PCB
inspections in the past few-months, Hunt said. V;
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Pnonn*) nd Training --v-v-----
Another important consideration in the stepped-up "en forcement program was the:.hiring .and training of ad ditional ;enforcement.personnel. Hunt said.** r-9j-.r"-. ,.ln many of . the regions, he. said, enforcement-personnel and-inspectors are.being-diverted from other.duties to allow
closer monitoring of PCBs. .. ci,"; H > r.s-n:q ->Hunt.said be is "virtually certain'1.there.will be3`.'a lot
more,'l.PCB inspections in;1980 than there were this year.
He also expects a concurrent increase in the number of civil
penalties and injunctions for PCB violations. . jtvtazi::
a-Jtegional .enforcement,personnel are becoming adept.at
choosing the.best--remedy;and.regu)alory tool to deal.with
hazardous chemical situations. Hunt said./Because the PCB
.rule acts quickly and effectively, it is certain to get more
frequent use, be said.~
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T1-*> 2o'>S"= ;*o
Premenufacture Notification..,rr
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EPA. RESPONDING TO COMMENTS. CHANGES . FORM, PROCEDURES FOR CONFIDENTIALITY, >- .
"The Environmental Protection'Agency October 16 re
proposed the form for filing premanufacture notifications,
incorporating changes that are expected to make completing
it 50 to 60 percent less expensive.
............
' The revised form'/ which is published in the Full Text
section of this'.issue, is expected to be less costly to fill
out because it is shorter and would require less detail than
the originally proposed version (44 FR 59764).
EPA first proposed the form and regulations under Sec
tion 5 of the Toxic Substances Control Act January 10 (Cur
rent "Report, January 12, p.'l797). Under EPA's premanu
facture notification program, which began July 1, manu
facturers are required to notify EPA 90 days before manu
facturing a new chemical.
Industry responded to the original proposal bv saving that
it would be burdensome and unnecessarily costly.
r,: EPA announced in May it would revise the form in a way
that would reduce the cost of completing it but would main
tain the agency's ability to perform risk assessments (May
. -18. p. 218).-
; ; , -
1= EPA's proposal also includes new procedures for sub
stantiating confidentiality claims. They would require manu
facturers to substantiate claims for all information claimed
as confidential at the time the notice is submitted (October
*12,*p. 1097,, *.:
--tr. .. . .
; *. >
it EPA also reproposed criteria (or supplemental reporting
under Section 8 of TSCA. Supplemental reporting provisions
detail what kinds of information and under what circum
stances EPA may call for information from the notice sub
mitter during the notice review period.
. EPA also proposed a form for exporters in addition to
reproposal of the form for importers and manufacturers.
In addition to reducing the level of detail in the form, EPA
also changed the customer contact provisions and the pro
cess flow diagram, two controversial sections of the form.
EPA's original proposal would have required the manu
facturer to contact potential customers to determine what
the uses of the new chemical would be. The reproposal only
asks the manufacturer to tel! how many commitments it
has for uses unknown to the submitter and what percentage
of the chemical's production would be involved.'
" EPA reduced the level of detail that would be required in
the process flow diagram. EPA said the process flow dia
gram now resembles block diagrams often published by
industry in trade publications. - -
v'The costs of completing the form are detailed in a report
prepared by an EPA contractor, A.D. Little Associates,
Cambridge, Mass. Copies of the study will be available
through the EPA Office of Industry Assistance within a few
weeks (October 12,-p. 1101). - " --
;
*"A 45-day comment period is provided for the reproposal.
Comments should include the docket number OTS050002E and be addressed to the Document Control Officer. Office of Toxic Substances (TS-793), .EPA,. 401 M St., rW., Washington, D.C. 20460. .................. .
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Asbestos , :r
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e'pa: CPSC .TO'SEEK TO ELIMINATE
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i AU. NONESSENTIAL USES OF ASBESTOS jV lif''
>: All nonessential uses of albedos in the United States would eventually be banned under regulatory approaches outlineo October 17 by the Environmental Protection Agen cy and the Consumer Product Safety Commission. , The agencys1 tentative approaches to the problem of con trolling commercial uses of asebstos are described in coor dinated advance notices of proposed rulemaking.
rpsr in its notice, says it intends "initially to seek the elimination of all nonessential uses of asoestos in consumer products irom wniCfl SiBsli5S libers are released" (44 FR 60057). The commission does not identify specific products or categories to receive priority attention in its rulemaking.
EPA, however, "has selected asbestos paper products and automobile and light truck brake linings as initial can didates" for regulation (44 FR 60061).
Regulatory Overlap
In a joint policy statement accompanying the advance notices, the two agencies cite the possibility of conflict and
^0-19*79
Copyright e 1979 by The Bureau of National Affairs Inc
om-79n/?wooso
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duplication of effort in. regulating asbestos uses (44 FR
60056).
i.iLr.;."- wr.'. -
CPSC has authority under the Consumer Product Safety
Act to take action against hazardous'consumer products.
EPA has somewhat broader authority, under .the Toxic
Substances Control Act to regulate manufacture, processing, distribution, use, and disposal of any hazardous substance.
The joint policy statement does not clearly define a divi sion of-responsibility'-between the agencies in regulating
asbestos uses, and their respective notices list many of the
same products as possible candidates for action. .-
- The agencies suggest that VCPSC's authority, may enable
it to reduce consumer exposure to asbestos-containing
products pending-more general proceedings initiated under EPA's broader program.'hs'or:.':. AD>.T S nr-;:--; t-
The EPA advance notice and the joint policy statement are
published in the Pull Text section of this issue. - - -
.
... . . . EPA: Broad Approach," ..,^"
EPA says its "broader approach" will involve analysis of
the cumulative "life cycle" risks presented by asbestos
products from mining to final disposal. EPA may decide to
ban or limit specific products or product categories, or to
limit the total amount of asbestos used each year, the agency
says. -- Alternatively, EPA says,"it may use a combination of the
two approaches, reducing the amount of annual use by 5 to 20
percent each year while banning selected products that pre
sent particular hazards.'""'.? r...............1
The category of asbestos paper products selected by EPA
for initial attention accounts for 30 to 40 percent of total
asbestos consumption, the agency says. Paper.products in
clude roofing and flooring products, tubes, tapes, insulating
sheets and blocks used in appliances, gasketsi /liters, and
general fire-proofing materials..,'..' - - . . '/I-
Friction products, EPA says, account for about.14 percent
of total asbestos use, primarily in brake.linings.'.".',.. .
EPA says acceptable substitutes are available or under
development for asbestos, brake`.linings..and for-many
asbestos]paper product uses.'
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' icsSJt--. : r.~ -Rik Analysis
t<i C.'i
EPA says it will-attempt to assess the'health risks
associated with asbestos use to identify " 'unreasonable risk'
on the basis of the availability of reasonable substitutes."
EPA's risk/benefit analysis will include such factors as
the need for the product, cost and availability of substitutes,
industry structure and employment,-energy, consumptiqn,
growth and.profitabilitylrana^market segmentation.",''] ,`T
CPSC, on the other band,''`does hot'intend'to employ quan
titative, estimates. of_canceri risks posed by. exposure to
asbestos fibers/-' Because.of_the_seriousness of thejnjury
associated withasbestos, CPSCfintends to ban all nonessen
tial uses.-'" v-'r'': -
"rruer'O vi: : .
The difference between the twoapproaches may be more a question of terminology than of.substance.. Although EPA, in its notice;-speaks of "unreasonable risks," rather than /nonessential uses," the agency later suggests that, when all "unreasonable risks have.been eliminated, the remaining products and uses will be."essential."
' Sections 6.'6. 8 of TSCA
EPA believes "that TSCA provides an effective means of
controlling the proliferation of asbestos use in the United
States." The agency is considering issuing rules under
various sections of TSCA, including:
A Section 8(a) rule requiring asbestos producers, im
porters, and processors to keep records and report on
CHEMICAL REGULATION REPORTER
various aspects of the industry, health effects, and worker
exposure; -t' r --' -
- = : - ' ' '.....
A Section 8(d) rule-requiring submission of all un-'
published health and safety studies on asbestos;
A Section 6(a) rule which may regulate processing,
storage, labeling, record-keeping, or distribution; and : -
A Section 5(a) rule requiring manufacturers to submit
premanufacture, notification for significant new uses .of
asbestos. "'l"
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.j *` :-vrr.' ` .CPSA Authority'
- *:;
Under the CPSA, the" commission may set consumer
product'safety standards, require warning labeling, ban
products, or. require repair or replacement of hazardous
products.
CPSC says it intends to issue a notice under Section 27(b)
of CPSA to require manufacturers to submit information on
certain asbestos uses. -
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In their joint statement, the agencies say they plan to
share -all- available data and to coordinate information
gathering to reduce the reporting burden on industry.
The agencies ask for comments on regulatory priorities,
their proposed approaches, risks and benefits associated
with specific uses, and a variety of other issues.
Comments on the EPA notice should be submitted by
December 19 to Joni Repasch, Record Clerk. Office of Toxic
Substances (TS-793), EPA, 401 M St.. S.W., Washington,
D.C. 20460. Further information is available from the In
dustry Assistance Office (TS-799), at the same address,
(800) 424-9065, or in Washington, D.C., 554-1404.
" Comments on the CPSC notice should be sent by December
17 to Office of the Secretary, CPSC, Washington, D C. 20207. For
further information, contact Francine Shachter, Office oi
Program ManagemenL CPSC, Washington, D C. 20207, (301)
254-6241.
......
" iz: Citizen's Petition Grimed ' ............
In a related development, EPA announced October 18 that
it has granted a petition from Glen Scott of Louisville, Ky.,
that the agency institute rulemaking to ban asbestos cement
water pipes (44 FR 60155).
-i ' '
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Since asbestos cement pipes are already under considera
tion in EPA's general commercial use rulemaking, the gran
ting of'the -petition involves no separate regulatory in
itiatives.
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- 'EPA says inits notice that it is also taking action to reduce
asbestos'contamination of drinking water under the Safe
Drinking Water-Act.~>-
" ttnttr.Kto it-on.:*-;.
Litigation
EPA BAN ON PCBs NULLIFIES INTENT OF CONGRESS FOR CONTROL. EDF CHARGES_____
The Environmental Defense Fund October 19charged that the Environmental Protection Agency violated the purpose of the Toxic Substances Control Act by defining polychlorinated biphenyls (PCBs) to include only concen trations of 50 parts per million (ppm) or more.
The charges were made in a legal brief filed in the U.S. Court of Appeals for the District of Columbia Circuit. The brief reiterates and amplifies assertions made by EDP when it filed its June 7 petition for review of the EPA ban on PCBs (Current Report, June 15, p. 420).
"The agency's actions in permitting virtually all of the 750 million pounds of PCBs currently in commercial use to con tinue to be used for many years into the future nullifies the effect of the ban, and defeats the congressional intent by in-
1019-79
Chemical Regulation Reporter <n**>79TV7VSOO.SO
000460