Document LpqLM06KnDENo4n9mGrGDjgQb

FILE NAME DuPont DUP DATE 1970 Sept 2 DOC DUP126 DOCUMENT DESCRIPTION Letter to Robert Gorson Thomas Jefferson Univ from James F. Morgan DuPont RE his Dissent to the Majority Opinion on Spray Application of Asbestos fc : a . esate isos . E. 1. DU PONT DE NEMOURS & COMPANY oe ENCOUPONATLU ENCOUPONATLU ve WILMINGTON DELAWARE 19833 EMPLOYEE RELATIONS DEPARTMENT HASKELL LABORATORY TOXICOLOGY TOXICOLOGY TOXICOLOGY AND INDUSTRIAL MEDICINE cc Members of the Ad Hoc on Spray Application of Commit Asbes CC Jesse Lieberman Chief Occupational and Radiologic Health Section City of Philadelphia 239 September 2 1970 fon ; : 7 . - Robert O. Gorson Professor of Medical Stein Center Physics Thomas Jefferson University 920 Chancellor St. Philadelphia Pa Dear Professor Gorson In connection with my dissent to the Aosfbetshteosmembers of the Ad Hoc Committee on SmparjaoyrAiptpyliocpaitniioonn of Fourth regarding the draft report that was discussed at the Meeting on August 31 1970 you have asked that I sub- mit a memorandum expressing my views with on the Specific Recommendation A I wish The to comment here- Asbestos Material page 7 and on the Elimination of Spray upon which the recommendation is preceding based paragraphs Paragraph 5 page 4 points out that it is difficult to ensure 100 containment of the spraying operation airborne asbestos material during This was established as Dr. Boucot after School and that Association in a visiting the of Mr. Wyman statement to a fact by the testimony of site of Martin Luther King Jr. of General Building Contractors the Committee August 31 1970 It is also a fact that neither the contractors public health agency has put forth the intense nor any that is required to overcome a problem such research effort this hygiene engineering has succeeded succeeded in as Industrial safely processing and devising procedures for using many many potentially hazardous materials _ such as beryllium uranium ore silica sand lead mercury etc. spraying Methods for spraying rial without containing insulating mate- emitting dangerous quantities of fibers from the site can most certainly be devised effort are expended by qualified provided sufficient time and engineering personnel A 240 R. O. Gorson Cont'd Page 2 . September 2 1970 . OS Similarly methods can be devised for the protection of persons spraying containing insulating material and other persons working on the site during the spraying An example of a precedent for the development of satisfactory safety in procedures is afforded by sandblasting of metal parts foundries metallurgical establishments shipyards scrap yards etc. It can now be done safely by using supplied helmets enclosures and ventilation systems that have been developed for the purpose . Similarly procedures and regulations can be devised to coat the sprayed insulation material and sion into air supply ducts thereby prevent ero- With respect to health protection dtiuorningofmaintenance work alteration of structures or demoli- structures the presence of sprayed asbestos- containing insulating material is only one part of the whole problem of dust dissemination of asbestos products These products may and exterior be encountered as structural board pipe insulation as and in floor tiles interior The tion of sprayed insulating material would elimina- eliminate the need for an not safe procedures in awareness of hazard and practice of maintenance alteration and demolition CONCERN FOR FIRE PROTECTION The material use of sprayed containing insulating is intended to protect structural members of from melting during accidental fires buildings It is intended to _ serious or fatal collapses during the fighting of fires prevent in office buildings schools hospitals and hotels The should hinder offer no adequate recommendation which protection of the would interfere Committee with or hibition of the use of structure from fire A pro- would leave containing material at this time as an alternative the use of a single material Although this material was reported to the Committee to have been approved by the Underwriters Laboratories series of laboratory tests of following a that the building effectiveness construction the fact remains tunity to use and to test it industry has not had an oppor- to its performance This on a long basis with respect structures in concern for adequate protection of case of fire indicates that the construction industry should have some alternative in the event the . sub- stitute asbestos material should fail either with to performance or adequacy of supply respect . R. O. Gorson Cont'd Page 3 os September 2 1970 . 241 Page 6 Paragraph 9 I choose to withhold at this time an active dissent from the draft statement that it is prudent for public health officials to assume that there is no level of concentration of airborne asbestos fibers below which adverse effects will not occur in population groups chronically exposed There was evidence furnished to the Committee that asbestos fibers like every other toxic agent can be than zero concentration without tolerated at some adverse response level greater Reference may be made to the reprint entitled Asbestos which was furnished to the Committee members W. Wright and appeared in the AMERICAN REVIEW and Health in 1969 It is by George OF RESPIRATORY DISEASE Vol 100 No. 4 pp 467-479 October 1969. There is definitely no occasion for dissent from the statement which follows the above the committee endorses the consensus of many experts that every reasonable to limit the discharge of asbestos . from all sources method fibers should be exercised into the environment SPECIAL RECOMMENDATIONS A. ELIMINATION OF SPRAY ASBESTOS : MATERIAL o m Acceptance of the statements made above would argue for the addition following parts 1 and 2 of this recommendation of a statement similar to the following unless the prospective prime contractor will furnish to the City of Philadelphia a detailed plan of procedure acceptable to the City whereby emissions beyond the site will be con- trolled to the limits expressed in Recommendation C 2 and will give assurance that a sealant coat will be applied over the insulating material on those surfaces which are to become a part of an air supply system Thank you for this opportunity of adding these remarks concerning my dissent to the record Very truly yours JFM on, a4 Jame F. Morgan Consultant Industrial Hygiene