Document LjDbN6281jxr0g4xXOX0ae4q

FILE NAME: Union Carbide (UC) DATE: 1984 DOC#: UC102 DOCUMENT DESCRIPTION: Letters from Mt. Sinai to the EPA with Cover Letter to the ORC Asbestos Task Force National Place, Suite 911 1331 Pennsylvania Avenue, N.W. W ashington, D.C. 20004 202-737-6330 Organization Resources Counselors, Inc. February 7 1985 Memorandum To: From: Subject: ORC Asbestos Task Force Darrell K. Mattheis Letter from Dr. Arthur Langer, Associate Director, Environmental Sciences Laboratory, Mt. Sinai, to Dr. John A. Moore, EPA, Concerning the NF:DC Petition for a Prohibition on the Use of Asbestos in Auto and Truck Brakes Thanks to John Marsh, I recently received a copy of a very interesting letter as described above. I think that Dr. Langer's opinion, as formulated in his letter to Dr. Moore, will be of interest to the members of this Task Force. Enclosed is a copy of the "Langer Letter". DKM/jt Enclosure UCC 004203 Copies of two letters from Dr. Arthur Langer, Associate Director, Environmental Sciences Laboratory, Mount Sinai Medical Center to Dr. John A. Moore, EPA Assistant Administrator, concerning the petition of the MRDC for a "Prohibition on Continued Use of Asbestos In Automobile Brakes" are enclosed. It Is Interesting that Dr. Langer considers the documentation In the petition to be "mindless and pure rubbish." More Importantly, however. It Is noteworthy that Dr. Langer recognizes the significant differences in risk produced by different fibre types nd industrial processes. This is the first time I have seen a statement by a member of the Kt. Sinai group that such differences exist. I don't know whether It represents a consensus among the Mt. Sinai scientists; on the basis of a recent conversation with Dr. Selikoff, I doubt it, but the letter might be useful In the `fchrysotlle defense" and in cases where Dr. Langer is a witness. Sincerely, UCC 004204 ' >> 4 Cfcranents c MtOCSTX/t3CUrJSS File # t . MDtJWr PTNaT.H^TCAI. (TOTO . L THE MOUNT SIN.A! . ED1CAL CENTER O N E CUSTAVE L.L E W !*>...r SE' YORK N.Y. 10029 Mount Sinai School of Medicine *The Mount Sinai Hospital * . tj Environmental Science* Lobo raion Cummmfi B atic Sciencet B udinf iP Eos 102 Street Wir York. Sete York 1002H i2:2< 50-0173 t.-t * . ' ! i>r .::c Tij.m c Substances Environmental Protection 637 E ast Tower - TS788 01 M Street, S.V. Washington, D.C. 20460 : o r r'e s t i c i r i e s Agency " Dear Jack: I have just read the NRDC petition for a ,,..vuu,, S itthh tthh"e T docume*n"t* l, th*t d*nat`1a re invoked toHyanppeojrotr tchoenier. TM ovn .rranent taken fro. verel of y ovn p.p.r*. / Do you really have to answer this petition? Sincerely, AML: j m cc: Dr. Steven Shapiro , **k I1 . Ci rrH i; ( C 875 UCC 004205 I * / M* ' V .V THE MOUNT SINAI MEDICAL CENTER ONE GUSTAVE L LEVY P U C E N E W YORK. N Y. 10029 Mount Sinai School ofMedicine "The Mount Sinai Hospital December 7, 1984 BnvirvnmtnUii Sci t n e tt .atom to o . a Cwarning! B atic S c itn c tt Buildup John A. Moore, BVM ' U V |P Cut 02 S trttt Stic Yor*. N r* Yor* /0029 Assistant Administrator for Pesticides f>rr ic end Toxic Substances S504I73 environmental Protection Agency rv*- ^ , 637 Cast Tower - TS788 " ** * * * * * - 401 M Street, S.W. -- teeusa j a low Smmbjc Washington, D.C. 20460 " Dear Or. Mooret It has been made known to me that my written remarks of October 11, 1984 concerning the Batural Resource Defense Council's Petition for a "Prohibition on Continued Use of Asbestos in Automobile Brakes" will enter, with other documentation, into the rule-aking docket along with the original petition. Z am therefore requesting that this letter be substituted as a formal critique. ' My concerns regarding the petition are many, essentially focusing on lack of insight and on an unseholarly approach to the problem: - The JTtDC claims that both epidemiological and pathological reports "have shown only recently that asbestos is one of the largest / single causes of environmental human cancer in the United States." This statement does not accurately reflect the literature. In support of this statement the petition cites BBS Secretary Califano who reported that approximately 171 of American cancer deaths over the next several decades will be "linked" to asbestos. There are approxiautely five hundred thousand cancer deaths per year In the United States which would roughly translate into 85,000 cancer deaths per year "linked to asbestos." Immediately following this statement is an attribution to Micholson and co-workers who have estimated that cancer deaths in the United States from asbestos will number some 8,500 to 10,000 per year over the next 20 years. The authors of this document fail to reconcile this order of magni tude difference in these figurest fall to resolve the proportion of excess cancers attributable to workplace exposuresj have not considered that if 8,500 cancer deaths will occur among 10-15 million "exposed" workers in different occupational settings, 85 thousand asbestos "linked" deaths means that everyone in the general population Is at the same level of risk. It seems farfetched; - Ij their discussion of mesothelioma and lung cancer, the KRDC authors use data from studies of insulation workers in their descrip- t UCC 004206 C287G . tJohn A. Koore, DVM 2. December 7, 1984 tlon of increased risk of asbestos diseases in expoatd population* Tht nature of the fiber exposure, fiber type, fiber dimensionality and fiber concentration ere significantly different vhen compared to workers maintaining end repairing brake pads. Sate for lnaulation workers way have little bearing for brake workers. These uncritically accepted as data applicable for all workers exposed to any variety of asbestos fibert * assertion that all asbestos fiber types are carcinogenic in humans is correct. Sowever, not all fiber types produce human mesothelioeu (no mesotheliomas have been reported amongst humans exposed to anthophyllite fiber in the workplace) and not all of the asbestos fiber types produce the same attack rates for broncho- genlC' carcinoma. While it is true that the three major varieties of asbestos need in the United States Induce both types of malignant tumors in experimental animals, industrial manipulation may elter outcome, "There is an attribution to a study conducted by my colleagues here in the Environmental Sciences Laboratory which revealed excess cancer mortality "in workers with short-term exposure-- one swnth or less of employment in an asbestos plant." This citation appears at the end of a paragraph which states that "People living in the ares of asbestos mines, mills, factories and even shipyards and family members of asbestos workers have become victims of mesothelioma despite what we would be considered light exposure -to the dust." The asbestos plant in Paterson, hew Jersey is believed, by many (including Seidman of the American Cancer Society) to have had workplace exposures approaching lOOf/ml. licholson occa sionally uses a figure of 35, 1 have used a figure of 50 but it is generally conceded the exposure levels were very high Indeed. One month's exposure during the second World War translates into a 500-1,OOOf/ml exposure day (10-hour shifts during the second World War). Using a 20-day work month this computes to a 10,00020,OOOf/ml exposure month. This would correspond to approximately a 2-5 year exposure in the occupational setting at the present 2f/ml level. Wo one would consider this a "trivial" exposure. Wo one would consider this a ^bystander" or "environmental" exposure; Zn the very next paragraph, on page 6 of the petition, the work of Harries, carried out in the Devonport shipyards of Great Britain,, is used to support their argument that mesothelioma may occur from "bystander" exposure*. Harries and colleagues shoved that the tearing out of asbestos fiber on shipboard results in aerosols which may approach 1,OOOf/ml in the immediate environment! Fiber measurements made during tear-out operations, aboard ship, haveahovn tens of f/ml of air in areas removed from the actual site of rip-out. Again, this is included to support the argument of the petitioners that "indirect occupational exposure" was sufficient to produce mesothelioma many years later. These Indirect measur- ments are considerably greater than those encountered in most workplaces today. Additionally, the fb<?r types encountered in UCC 004207 ) John A. Moor, VH 3. Dc*at>er 7, 1984 P .t.r.o B i . l io l ; *" . i n d U * i 1,1th m ? 2 . Altbonh C hrysotil .r o d u e t humsn * o o th l io s cm k, J . xposd to e ro c ld o llt *d " * " C S i 't i T f t l r t io r c h r y o t l l . P . . . B0*l t * . I,r .k w y lo er * s* 'S S 'i S S s * ';*-i* tio n j . i riii .-> >. - The * * Ilrt ^ r i `r1n ^ u T l " l 3 3> i . u . . j o r i.k ;L i.= tio A tcr u h ` " 7 ; " ; ; , 1 2 2 .^ - t u t T . r t . < S ^ u S S - V f 1 `~ S . Itm t CriC .r j r r i l i . * .ri ctloM l tU k. ,, r , c .ld .r r l.k P B it . l d u .try . T. * l * L . "s r!.^ ln t ir * t* d to y l ld * ** * ^ * * o it *d * l* d f *b er l. h4.ct h .r ul dt stio n f o r . e to 5ii%l " i b T u s .d srorkor d st ) y . . for chry.otil. flbr suraots, couplcd Ith th rU tlv^7 I ts hrodst n t x t. Ti ld s odl h lth w*J **** r * c n t WC doeuant (198*) Ths shortccm lngs ^ rher thsn w EP> tn t* f l b i r . 1 o c l r c u r i t . n = . i TM # t d,, th , . t t r l h t . t l th. ,, ,, ro iriti. . ,,o u d t. t . S ^ C . - - thf. trl . -' *. . P T i " '^ . r . . , l t ,, r k . r , ~ to th` i *, *..kP(li-vri * t) tT& UCC 004208 o John A. Moore, DVM December 7, 1984 cry tissues, was reported by myself. I believe thia working popula tion to be at rlak but I also believe this risk to be leas then encountered vltb other fiber types In other work environments) - here are the data to shoe that substitute friction product notarial are safe"? Vhat happens to e.g., a m i d fiber when sheared from a brake surface?) *' " "sintered jeetal" compositions considered safe? fintered hard metal materials are nov laplicated in pulmonary disease (hard- metal disease). ^ *?r** mlth the petitioners that there are auray Instances where brake maintenance and repair subjects workers to asbestos fiber exposure which Increases their neoplastic risk. There Is no question that this occurs and that the risk is measurable. 1 similarly believe that there are no data to support that such risk exists for the general population. Exposure to the general population may occur and that the control of asbestos emissions chould be Instituted. However, we have no data to support the contention that it represente a "public health haxerd." I believe it would be prudent to prevent such exposures from occurring to the general population even though there are no data to support that such exposures are hazardous. The federal courts have noted that one say rely on "general data" in making certain decisions. Therefore, If this petition is to U contldtrtd ti "gsntrsl approach" to the asbestos problem then, presumably, the Environmental Protection Agency will base its decision on courtroom law. As it now stands, one can only appeal for the decision to be based on the concept of "prudence" rather than science. The decision phould be made on the social basis and not a pseudo-scientific one. This issue is a very important one and should not be approached in an uoscholarly fashion. My strongest objections focus on the arfauae of data and the uncritical use of these data in supporting certain contentions. It Is a form of quasi science which we, as environmental scientists, cannot afford or allow fo go unchallenged as it reflects upon all of us and our work. - AKLijm Arthur M. Langer, Associate Professor of Mineralogy Associate Director, Environmental Sciences Laboratory UCC 004209