Document Lo8NgeZBJXEBnNw30mGqy6Jp7

FILE NAME: Union Carbide (UC) DATE: 0000 DOC#: UC101 DOCUMENT DESCRIPTION: Unpublished Report - Asbestos SPU/CPU Recommended Assumptions - Health and Regulatory Matters ASBESTOS SPU/CPt) RECOMMENDED ASSUMPTIONS - HEALTH ANO REGULATORY MATTERS INTRODUCTION (Figure I) The health hazards, governmental regulatory actions, and other potential financial exposures such as product liability and legislated penalties will be key considerations in our strategic planning sessions on asbestos. This discussion will give you a brief overview of the important considerations and suggest planning assumptions in all of these areas except product liability which will be left to others. Details will be provided as needed. HEALTH HAZARDS . (Figure II) Asbestos is a fibrous silicate mineral. Six types are generally included in regulatory actions, i.e. chrysotile, crocidolite, amosite, tremoiite, anthophyllite, and actinolite. The first three types are the commercial products. Tremoiite is important mainly as impurity in many talcs. About 95 of all asbestos used is chrysotile. Our asbestos is short-fiber chrysotile (Figure III) There are four diseases connected with asbestos exposure. There are asbestosis, bronchogenic (lung) cancer, mesothelioma, and gastrointestinal cancer. Asbestosis is. a progressive lung fibrosis similar to silicosis and black lung disease. It is not a malignancy, but when once present, may proceed slowly or quite rapidly. Latent period is generally 15 years or more, even after heavy exposure. Lung cancer is a well-known and highly publicized disease. *t is well established that there is a synergistic interaction between asbestos and smoking as a cause for lung cancer. Heavy smoking asbestos workers run a UCC 004150 -2- HEALTH HAZARDS (Cont'd.) risk about 90 times greater than non-smokers. Asbestos causes very little increase in cancer risk for non-smokers. Latent period for this type of cancer is 20-50 years after exposure. Mesothelioma is a very rare, nearly always fatal, cancer of the pleural or peritoneal areas. There are about 5000 confirmed cases in medical history. Latent periods are 20-50 years. This disease is the crux of the asbestos cancer problem since it apparently can be caused by short, relatively low exposures and is not smoking related. It is mesothelioma that is the concern in the' recent school' ceiling and 1/ hair-dryer publicity. Until recently it had been considered basically an asbestos-caused disease. This is now questionable since it has been found to have been present for generations in several villages in Turkey where no presence of asbestos has been established. Statistical excesses of gastrointestinal cancer of marginal significance have been found in epidemiological studies of several cohorts of asoestos workers but not in other studies. It has been accepted as asbestos-related for workmen's compensation cases in Canada (Ontario) and has been included as such in some recent proposed legislation. `.-t. : Although it is generally agreed that all of the commercial types of ^ asbestos can cause asbestosis, there is a great deal of controversy in the cancer area. Strong differences of opinion exist among responsible author ities as to whether all of the asbestos types present the same cancer hazard or whether there are significant differences among them. Similar differences exist over the effect of fiber size on the degree of hazard, particularly with regard to fiber length. Options range from 1.) crocidolite longer than ' UCC 00415 i -3- HEALTH HAZARDS (Cont'd.) 5p as the main cause of mesothelioma to 2.) any respirable mineral particulate with a length longer than three times the diameter is a cancer hazard. If the later view is true, any hardrock mining operation is a candidate for "asbestos" type regulations. There has been a great deal of research done in the last few years and much more is in progress. No radically new discoveries have occurred, however, and there are no indications' that any are imminent. It seems reasonable to assume, for planning purposes, that there will be no large changes in the perception of the health hazards presented by asbestos. When the health concerns first became well known in the mid-60's, Union Carbide had several small-scale animal tests run by Carnegie-Mellon Institute. These tests indicated that "Calidria" was about the same as the other chrysotile tested and this has been our position since that time. . There have been substantial improvements in test procedures since that time and some concerns have been expressed by medical authorities that very fine fibers (which are the predominant type in "Calidria") may represent a greater biological hazard than thicker fibers. It is suggested that we continue with the assumption that "Calidria" is no different from other chrysotile but seriously consider that it may be prudent and appropiiate to expand our test base. GOVERNMENTAL REGULATORY ACTIONS Regulatory Approach for Carcinogens (Figure IV) It is evident that under certain circumstances, at least, asbestos can be a carcinogen. Up until the last five years, the concept of a thresh hold limit exposure, i.e. an exposure level below which no measurable adverse effects occurred, was well accepted in toxicology. In the last UCC 004152 -4- GOVERNMENTAL REGULATORY ACTIONS (Cont'd.) Regulatory Approach for Carcinogens (Cont'd.) several years, however, the new concept that such a threshold limit does not exist for carcinogens has been advanced and has been accepted by the regulatory agencies as a basic principle. An additional idea that zero risk is an appropriate objective for an occupational or environmental standard (virtually without regard for cost) has been advanced and has also received some significant acceptance. The combination of these concepts leads to a position, advocated by some elements of organized labor at the Washington level and by certain activist groups, that anyone who releases a single asbestos fiber or radon molecule, for example, is willing to kill people for a profit. This position is taken even where the incremental increase is an extremely small fraction of the naturally occurring background and/cr is completely masked by fluctuations in the background level. This is obviously a highly emotional area. Industry has responded to this position with the concept that life is a series of risks, i.e. there is no such thing as zero risk, and that actions should be assessed in terms of relative risk. Two areas of relative risk should be considered: 1. Incremental decrease in risk per dollar spent to achieve such increment. 2. Level of risk achieved in relation to other risks acceptable to society. * The first of these comes close to but avoids direct reliance on the very emotional dollars per human life issue. It stresses the most efficient allocation of limited resources and the effect of diminishing returns. UCC 004153 -5- GOVERNMENTAL REGULATORY ACTIONS (Cont'd.) Regulatory Approach for Carcinogens (Cont'd.) The second point emphasizes that a product supplied has a valid and valuable societal benefit or it would not be used. Its risk is the same as (or much lower than) other comparable risks commonly accepted by society and its use should be judged on that basis. This basic approach was endorsed by Union Carbide in their response to the recent OSHA generic ^ standard for carcinogens and would seem to be equally applicable to asbestos. As a corollary to this approach it is suggested that consideration be given to ways to minimize dust exposure for the users of our product. This would include better packaging and means of delivering the product to the customers, treatment of the product to render it dust controlled in itself, and marketing emphasis on end uses where free fiber generation is minimized or eliminated. (Figure V) This problem of how to propertly regulate exposure to carcinogens , could be greatly reduced if the level of risk at low exposures could be measured. Unfortunatley, the expected incremental increase in cancer at these exposures cannot be distinguished from variations in the back ground level and there is no reaT prospect that this will change in the foreseeable future. Epidemiology requires, too large a cohort to be a practical approach, although the NRC is now looking at the feasibility of a detailed study of 250,000 people. The only real way to a definitive scientific answer would appear to be through a detailed understanding of the mechanism of cancer. This is most likely to be many years away. The net result, and this is a critical point to consider, is that regulatory activities for carcinogens are largely a matter of public policy, not_a_ UCC 004154 -6- GOVERNMENTAL REGULATORY ACTIONS (Cont'd.) Regulatory Approach for Carcinogens (Cont'd.) response to scientific data. Estimate of Future Regulatory Actions (Figure VI) Public policy in the matter of carcinogen regulation is not well defined and is changing fairly rapidly. In the past, the different regulatory agenices with different statutory authority and responding to different pressures have, not surprisingly, developed somewhat different approaches. Generally there has been a common feature stopping short of zero risk such as the ALARA ("as low as reasonably achievable") policy of the NRC and the'lowest level technically feasible" followed by OSHA. Approaches of this type have the common problem of representing a moving target for compliance and can be subject to widely different opinions on what is reasonable or feasible. In the last year or so with the advent of the "inflation fighters", Executive Order No. 12044, the Regulatory Analysis Review Group, and the court decision on the benzene standard, the regulatory agencies, some willingly, and some reluctantly, are being forced to take a more rational cost effective approach to regulations. Alternative approaches must be considered and the choices made must be justified. This will not stop the development of new regulations but will strongly tend to keep them from going to extremes. (Figure VII) This analysis of the health hazard and regulatory situation has been used to predict the general trend of regulations over the next several years at which time it is reasonable to hope that they will be UCC 004155 -7- GOVERNMENTAl REGULATORY ACTIONS (Cont'd.) Estimate of Future Regulatory Actions (Cont'd.) stabilized. Details for each agency are provided in Figure XI which will not be shown unless requested. The conclusions are: 1. OSHA Standard of 0.5-1.0 fiber/cc TWA. 2. Other regulations not substantially more strict than at present. (Figure VIII) EFFECT OF SUBSTITUTE PRODUCTS ' . Our products which compete with other asbestos and our products which complete with non-asbestos materials are both susceptible to replacement by substitute materials and by alternative products. The viscosifier portion of the business where the user would only have to return to the material we displaced is obviously more vulnerable. Substitution may be mandated by law or regulation or it may be done by the user for a variety of reasons. Only mandetory substitution will be considered here. The impact of voluntary customer substitution is a marketing question and will be left to others. ' As a general principle, if two available products are equally cost effective and one of them is clearly less hazardous, it is obvious that the less hazardous one is the best choice. A possible exception to this exists if both are at such a low level of risk that the difference has no practical significance. __ The practical application of this general principle is complex for both regulators and product users, particularly when emotional, uninformed judgments are made. In the area of regulations, several small foreign countries have used the ban approach. A proposed specific time frame in England to phase out certain products has been modified to a generalized cost-effective criteria. An OSHA proposal under the generic carcinogen standard which would ban products UCC 004156 -8- EFFECT OF SUBSTITUTE PRODUCTS (Cont'd.) where OSHA decides a suitable substitute is available has been strongly attacked and appears likely to be beyond their statutory authority. Union Carbide elected not to go to court on a CPSC ban of asbestos-containing tape joint compounds. It is my best judgment that mandatory substitution will not be a serious problem. (Figure IX) RETROACTIVE LEGISLATIVE PENALTIES Some past uses of asbestos, before the hazards were understood, have resulted in several current serious problems. Examples are high exposures in World War II shipyards and the damaged ceilings in some schools and public buildings. In many cases the persons directly responsible cannot be identified or have long since gone out of business. The problem is who, in this time of strong Federal budget restraints, should be made to pay to correct the condition Congress has tended to react to these problems by broad based taxes or penalties on the industry with little regard for responsibility for the particular problem. One example is the Miller-Perkins Bill that proposed a retroactive penalty on asbestos sales in the 1945-1965 period to pay for testing in connection with the school ceiling problem. Hopefully, this has been modified. Another is the Fenwick Bill relating to compensation in lieu of third party liability claims. This is 1n the form a a very sizeable ($325/ton) tax starting in 1980 based on the manufacture of certain products starting in 1965. This is just starting through committee. Union Carbide was a small, late arrival in asbestos sales and much of our product has been used under strict regulations. On this basis it is suggested for planning purposes that we assume that we can continue to keep the impact of this sort of thing on UCC to a reasonable minimum. (Figure X) UCC 004157 - -9- SUMMARY AND CONCLUSIONS The various approaches suggested for health-related matters are summarized for convenient reference in Figure X. In connection with these suggestions, it should be noted that over the past few years the Asbestos business has committed essentially the full time efforts of one man to work with health and regulatory matters. These efforts have frequently proven to be effective in the avoidance of unnecessary overregulation. It is my opinion that this level of activity will be needed for the next year or two to achieve the above-noted assumptions. They will not just happen if we leave our problems to others. UCC 004158 ASRFSTOS SPLI/CPU ASBFSTOS HEALTH HAZARD, REGULATOR! AN? F1i'ift'irItl 1HERAT IOHS. 1. He a l t h h a z a r d s t o w o r k e r a n d e n v i r o n m e n t . 2. Go v e r n m e n t a l r e g u l a t o r y a c t i o n s . (Fe d e r a l , St a t e a n d Lo c a l ) 3. Po t e n t i a l a d d e d f i n a n c i a l e x p o s u r e s , a . product liability . B. l e g i s l a t i v e p e n a l t i e s UCC 004159 FIGURE I flSRFSTOS TYPES . \ Ch r y s o t i l e * Cr o c i d o l i t e X Am o s i t e ) Tremolite An t h o p h y l l i t e Ac ti no li t e (Co m m e r c i a l t y p e s ) (Im p u r i t y in m a n y t a l c s ) (Ho l o n g e r p r o d u c e d ) (La b o r a t o r y c u r i o s i t y ) *UCC "Ca l i d r i a " p r o d u c t is s h o r t -f i b e r c h r y s o t i l e ft FIGURE II UCC 004160 ASBESTOS-RELATED DISEASES As b e s t o s is Lu n g Ca n c e r - (Lung f i b r o s i s ) - (Ba s i c a l l y c i g a r e t t e smokers only) Me s o t h e l i o m a - (Ca n c e r of t h e p l e u r a a nd peritoneal regions) Ga s t r o i n t e s t i n a l Ca n c e r - FIGURE I I I UCC 004161 CARCINOGEN CLICHES 1. Th e r e is no s a f e l e v e l of e x p o s u r e t o a CARCINOGEN, 2, Ze r o r i s k is an a p p r o p r i a t e r e g u l a t o r y a n d ENVIRONMENTAL STANDARD. A n y RELEASE OF A CARCINOGEN, REGARDLESS OF HOW SMALL, PUTS SOMEBODY, SOMEWHERE AT AN INCREASED RISK. INDUSTRY RESPONSES. 1. L ife is a s e r i e s o f r i s k s . Th e r e is no s u c h THING AS A ZERO RISK EXISTENCE. 2. Re l a t i v e r i s k s h o u l d b e a k e y c o n s i d e r a t i o n . A. In c r e m e n t a l d e c r e a s e in r i s k p er DOLLAR SPENTTO ACHIEVE SUCH DECREASE. (LFFICIENT USE OF LIMITED RESOURCES.) ' B. Le v e l of r i s k a c h i e v e d in r e l a t i o n TO OTHER RISKS ACCEPTABLE TO SOCIETY . A PRODUCT THAT IS USEFUL AND BENEFICIAL TO SOCIETY SHOULD BE JUDGED ON THE RISKS IT PRESENTS IN COMPARISON TO OTHER RISKS COMMONLY ACCEPTABLE TO SOCIETY. ********************************************************************************** lire PRODUCT DIRECTIONS 1, 4PHASIZE DUST CONTROLLED "Ca LIDRIA" ASBESTOS S ts AND MEANS TO DELIVER THEM TO CUSTOMERS 2* Em p h a s i z e e n d u s e s w h e r e f r e e f i b e r g e n e r a t i o n is-m in im iz e d or e l i m i n a t e d . UCC 004162 FIGURE IV CURRENT SCIENTIFIC SITUATION RISK.FROH LOW EXPOSURES TO CARCINOGENS 1. No WAY IN THE FORESEEABLE FUTURE TO OBTAIN A SCIENTIFIC ANSWER TO THE EXTENT OF CANCER RISK AT VERY LOW EXPOSURES, 2, Re g u l a t o r y a c t i o n b e c o m e s a m a t t e r of PUBLIC POLICY, NOT SCIENCE. 3. Pu b l i c p o l i c y is n o t y e t w e l l d e f i n e d re carcinogens. FIGURE V UCC 004163 1FVFI flPMENT OF PUBLIC POLICY Pa s t Ac t i o n s OSHA - AS LOW AS TECHNICALLY FEASIBLE, i'lRC " As LOW- AS REASONABLY ACHIEVABLE. (AURA) Proble m 1. Mo v i n g t a r g e t f o r c o m p l i a n c e . 2. Va g u e n e s s re w h a t is Tr e a s o n a b l e or "f e a s i b l e '7 . Re c e n t Im p a c t s . 1. "In f l a t i o n f i g h t e r s , Ex e c u t i v e Or d e r L.Q Re g u l a t o r y An a l y s i s Re v i e w Gr o u p , c o u r t nFrisiON ON OSHA BENZENE STANDARD. 2 . Fo r c i n g r e g u l a t o r y a g e n c i e s t o l o o k at ALTERNATIVE APPROACHES, RELATIVE RISKS AND COST EFFECTIVENESS. 3. Re s u l t - m o r e r e a l i s t i c , "l e s s e x p e n s i v e " REGULATIONS t o GIVE THE SAME BASIC LEVEL OF WORKER PROTECTION. FIGURE VI UCC 004164 FSTIMATE OF FURTHER REGULATORY. IMPACTS ON THE ASBESTOS BUSINESS 1. OSHA St andard of 0.5-1.0 f i b e r /cc TWA. 2. Ot h e r r e g u l a t i o n s n o t s u b s t a n t i a l l y m o r e STRICT THAN AT PRESENT. figure vii UCC 004165 THF PROBLEM QF SUBSTITUTJ M 1, Bo t h b u s i n e s s a r e a s s u s c e p t i b l e t o s u b s t i t u t i o n : a . Co m p e t i t i o n w i t h a s b e s t o s . b . Co m p e t i t i o n w i t h .o n -a s b e s t o s ! 2. Ge n e r a l p r i n c i p l e : Two p r o d u c t s e q u a l l y c o s t e f f e c t i v e - c h o s e ONE THAT IS LEAST HAZARDOUS. (POSSIBLE EXCEPTION - BOTH HAVE RISKS TOO LOW TO BE OF PRACTICAL SIGNIFICANCE.; . Pr a c t i c a l p r o b l e m : How t o d e t e r m i n e e q u a l c o s t e f f e c t i v e n e s s . Re g u l a t o r y a c t i o n s : Oc c a s i o n a l m a n d a t o r y s u b s t i t u t i o n s in p a s t . Pr o p o s e d i n .CSHA..g e n e r i c s t a n d a r d . Best judgment - mandatory substitution will j NOT BE WIDESPREAD._________ ________________ ____1 5. Cu s t o m e r a c t i o n s : Marketing q u e s t i o n . figure v i i i UCC 004166 FUTURE LEGISLATIVE ''FUIES" - PAST A$BESIQSJSE 1. Pa s t u se s h a v e l e f t us w i t h p r e s e n t p r o b l e m s , a , He a v i l y e x p o s e d Wo r l d Wa r II s h i p y a r d WORKERS. b . Da m a g e d s c h o o l c e i l i n g s , 2, Ca n 't i d e n t i f y t h o s e r e s p o n s i b l e . .a . Th i r d p a r t i e s . b . Out of b u s i n e s s . c. Re c o r d s l o n g s i n c e l o s t or d e s t r o y e d , Qu e s t i o n : Who p ays t o c o r r e c t t h e s e c o n d i t i o n s ,,?. 3, In t h e s e d a y s o f "i n f l a t i o n f i g h t e r s " Co n g r e s s has tended towards broad based taxes or penalties, A. Pe r k i n s -Mi ller " r e t r o a c t i v e t o an 1945. Pa i d by a s b e s t o s p r o d u c e r s . B. Fe n w i c k - p r e s e n t t a x b a s e d on 1965 a n d DNWARD USES. SUBSTITUTE FOR PRODUCT LIABILITY ASSUMPTION WF CAN CONTINUE TO HELP THF IMPACT OF THIS, SORT OF THING ON Iil.(. TO A REASONABLE MINIMUM.1 UCC 004167 FIGURE IX ASBFSTOS SPU/CEU SUMMARY OF Sllf.fiFSTFTl APPROACHES FOR HFfll TH RFI flTFT] HATTERS RASir. ASSUWPTIODS 1. 1$0 NEW RESEARCH SHOWING ASBESTOS TO BE MUCH MORE HAZARDOUS THAN PRESENTLY CONSIDERED. a . As b e s t o s in g e n e r a l . b . UCC "Ca l i d r i a " r e l a t i v e t o o t h e r a s b e s t o s . 2. OSHA St a n d a r d of 0,5-1.0 f i b e r /cc TWA. No m a n d a t o r y substitution. ' 3. Ot h e r r e g u l a t i o n s n o t s u b s t a n t i a l l y m o r e s t r i c t t h a n at p r e s e n t . No widespread use of bans or widespread mandatory substitution. 4. "Af t e r t h e f a c t " l e g i s l a t i o n f o r p a s t u s e s w i l l n o t h a /e a s i g n i f i c a n t i m p a c t on t h e UCC a s b e s t o s b u s i n e s s . PRODUCT DIRECTIONS. 1. Em p h a s i z e d u s t c o n t r o l l e d "Ca l i d r i a " a s b e s t o s p r o d u c t s AND MEANS TO DELIVER THEM TO CUSTOMERS. _ 2. Em p h a s i z e end u se s w h e r e f r e e f i b e r g e n e r a t i o n ;is m i n i m i z e d OR ELIMINATED. ADDITIONAL,ACTM, . 1, Co n t i n u e d i r e c t a c t i o n t o w o r k t o w a r d s r e a s o n a b l e , REALISTIC REGULATIONS TO GIVE GOOD WORKER PROTECTION. (Ap p r o x i m a t e l y o n e m a n , f u l l t i m e .) ` /. _ ......... _______ ~ '' ' _ ____ ___ __ _____________ ___ ___ CtRIIRF _V UCC 004168 STATUS OF STATF AND FEDRAL REGULA1 M ACTiOWS"'IMPACTING ON ASBESTOS. (p a r t 1) QSHA I. A s b e s t o s St a n d a r d 1. Pe r m a n e n t s t a n d a r d in e f f e c t s i n c e Ju n e 1972. a .) 2 f i b e r /c c TWA;. 10 f i b e r /cc c e i l i n g . 2. Re v i s e d p r o p o s a l m a d e o n Oc t o b e r 9, 1975, Action still pending. .... a ) 0.5 f i b e r /c c TWA: 5 f i b e r /c c c e i l i n g ,...... b ) Ac t i o n in i ate s u m m e r 1979-AI THE EARLI.E&I. . c) Best g u e s s - 0.5-1.0 f i b e r /c c TWA; 5 f i b e r /cc ceiling. II, P r o p o s e d G e n e r i c S t a n d a r d f o r C a r c i n o g e n s . 1. Co u l d i m p a c t v i a m a n d a t o r y s u b s t i t u t i o n a n d registration provisions. 2. Best, g u e s s - n o m a n d a t o r y s u b s t i t u t i o n .......... m. L II. III. N E S H A E S . ..................... ,................................ - 1. St a n d a r d for a m b i e n t a i r d i s c h a r g e a n d w a s t e d i s p o s a l p r o m u l g a t e d in 1973-1975. ...................... a . Pr e s e n t l y a "n o v i s i b l e e m i s s i o n s " c o n t a i n i n g a s b e s t o s s t a n d a r d ........................... b . Wil l b e r e p l a c e d w i t h a r e a s o n a b l e n u m e r i c a l s t a n d a r d . Se v e r a l y e a r s a w a y . Clean Wa'ter-.Acj- ............ . .................................. . - - 1. Co n t r o l s p l a n t e m i s s i o n s . No m a j o r c h a n g e s o r m e w impact anticipated. RECRA........................ ..... 1, As b e s t o s w a s t e ,d i s p o s a l h a s s o .f a r b e e n e x e m p t e d d u e t o c o v e r a g e b y NESHAPS. Co u l d c h a n g e a n d b e a p r o b l e m . UCC 004169 f i g u r e XI STATIIS'OF STATE 'ANTI FEDERAL REGULATORY ACTIONS IHPACTNG ON ASBESTOS, (p a r t 2) iv. m _ ................................ 1. Wh o l e g u e s t i o n o f t h e n e e d f o r f u r t h e r r e g u l a t i o n s is UNDER STUDY. TENDING TO MOVE SLOWLY. - 2. As b e s t o s i n c l u d e d in g e n e r i c l a b e l l i n g d e l i b e r a t i o n s . Over al l Assessment - W ith,continued effort we can keep the IMPACTS WITHIN REASONABLE BOUNDS.... CM ......... I. B a n n e d a s b e s t o s in t a p e j o i n t c o m p o u n d s a n d f i r e p l a c e l o g s . II. Le f t s c h o o l c e i l i n g s t o EPA. III. Ab o u t t o c o n c l u d e t h a t c o n s u m e r s w e r e o k a y w h e n h a i r DRYER PUBLICITY OCCURRED. Ov e r a l l As s e s s m e n t - Our b o u n d p r o d u c t s w i l l n o t b e s e r i o u s l y IMPACTED. I. Re c e n t l y i s s u e d s h i p p i n g r e g u l a t i o n s . a . Be t t e r p a c k a g i n g n e e d e d -.c o s t ?......... b . Sa m e p r o b l e m s in s p e c i a l c u s t o m e r a r e a s . Ov e r a l l As s e s s m e n t - Su b s t a n t i a l n e a r f u t u r e c o s t s .. Sh o u l d TAKE CARE OF PROBLEMS FOR CONSIDERABLE STATES. TIME. ~ ................ Ov e r a l l As s e s s m e n t - St a t e a c t i v i t i e s p a r t i c u l a r l y in i m p l e m e n t i n g RECRA c o u l d p r e s e n t s e r i o u s p r o b l e m if not HANDLED AS THEY OCCUR. ASSUME..THAT.THIS. WILL BE' DONE. UCC 004170 FIGURE XI