Document MG4MbJ4EYjygMk72k3GeY7j0L

FILE NAME: Union Carbide (UC) DATE: 1972 Mar 10 DOC#: UC218 DOCUMENT DESCRIPTION: Letter from Union Carbide to Reichhold Chemical Industries, Inc. RE Asbestos with Sampling Results UNION CARBIDE CORPORATION M ININO AND M ETALS D IV ISIO N 2 7 0 PA RK A V EN U E, NEW YORK*. N. Y. 10017 PLAIN TIFFS EX H IB IT Union Carbide 200 J a k es W. Rawtinos xe ' r a n w o n Reichhold Chemical Industries, Inc. 701 - 707 Woodward Heights Blvd. Femdafe, Michigan 48220 March 10, 1972 Attention* M r. R. C . Sulick, Technical Director Dear Sirs: M an/users of asbestos have become justifiably uneasy about recent federal regulations and proposed regulations pertaining to the use of asbestos products. Unfortunately, the publicity given to this governmental activity has tended to be of a sensational nature and has done little to place the question of asbestos toxicology in logical perspective. I take this oppor tunity, therefore, to state our firm belief that Union Carbide Corporation can comply with the regulations now applicable to our asbestos operations and with a ll reasonably anticipated additional regulations. Moreover, we believe that our R G -244 customers can, without un due burden, comply with these regulations as they apply to their operations. In this regard, it is our belief that if your facilities are ventilated to provide the protection required under present regulations against styrene fumes and amorphous silica dust, that you w ill also meet the standards established for asbestos. With regard to the toxicity of asbestos, it is important to note that asbestosis and statistical excess occurrences of bronchogenic carcinoma have occurred only in connection with massive long term exposures to asbestos dust. The risk of this type of exposure is usually in asbestos mines and mills and in manufacturing operations such as floor tile plants where asbestos usage may vary from 15,000 to 30,000 tons per year. The .risk of long term massive exposure is not typical of operations utilizing RG-244. As you are well aw are, RG-244 is used in relatively small quantities and is introduced as a small fractional addition to a strong binder resin on an intermittent basis. At the present time, regulations pertaining to asbestos exposure are in effect under the O c cupational Safety and Health A ct. In addition, proposed permanent standards under this Act were published on January 12, 1972 and are now under review . Also, proposed regulations concerning asbestos emissions to the atmosphere under the Federal Clean A ir Act are under review. The ulti late scope and content of the regulations and standards under review should be determined by mid-year. At that time, we w ill be prepared to provide compliance infor mation and assistance to our customers relative to newly adopted regulations. 27 Reichhold Chemical Industries, Ine. -2- u March 10, 1972 It is clear that the main thrust of the OSHA standards will be a limitation on exposure to airborne concentrations of various substances including amorphous s ilic a , styrene and asbestos. Under the OSHA regulations now in effect, the basic asbestos exposure limit for any employee is 5 fibers per milliliter on an 8 hour time weighted average. This limit is known as a thresh old limit value, or TLV . The present TLV for amorphous silica is 20 million particles per cubic foot, or 80 milligrams of S i0 2 per cubic metr with the weight usually limiting. A lso , TIVs have been established for many other substances, a ll designated as "air confan'-iants", such as styrene, mica, talc and coal dust. The present OSHA regulations applicable to these con taminants indicate engineering methods should be utilized to obtain dust or fume control to the prescribed level where this is feasible. However, respirators can be used to control ex posure. The OSHA rules now applicable to esuestos may be summarized as follows: Airborne Concentration (1) 8 Hour 15 Minute Exposure (2) Exposure (3) 5 max. 10 max. Required Mask Type None required Typical Mask (4) 25 max. 250 max. O ver 250 50 max. 500 max. -- U .S . Bureau of Mines Schedule 2 IB. Negative pressure on breathing. Covers nose and mouth. Willson Model 1009 with R-520 Fi Iter and M -S -A N o. 86432 with Type H, Ultra Filter and others U .S . Bureau of Mines Schedule 21B Powered fiIter positive pressure. Persona! Environment Sys tems, Inc. Hood 330 or 351 with 1900 Series filter U .S . Bureau of Mines Schedule 19B Type C positive pressure, air supplied. Wit Ison GA2H M -S -A LeadFoe and others. (1) Fibers per m illiliter greater than 5 microns in length, as determined by the membrane filter method at 400-45QX magnification (4 millimeter objective) phase contrast illumination. (2) 8-Hour time weighted average. (3) 15 Minutes in an hour for up to 5 hours in on 8-hour day. (4/ Not a complete list, but a list w ill be sent upon request. ^ o Reehhold Chemical Industries, Inc. -3- March 10, 1972 Experiments which we recently conducted indicate that the TLVs for both asbestos and amor phous silica may be exceeded during the introduction of the material into unventilated resin mixing tanks. The ange of readings for asbestos and amorphous silica during the mixing P^ ,ti f n.Mere' reV ef v* V / 1.4 to 11.5 fibers per m illiliter (average 5 .0 } und 2 4 .0 million to 3 9 .0 million particles of silica per cubic foot (average 30 m illion.) Other readings for asbestos fibers were as follows: Operation Spraying polyester resin in styrene with chopped fiber glass - boat hull and shower stall fabrica tion % Asbestos in Material 0 .4 to 0 .5 Fiber Count Range per ML________ 0 .8 to 1.4 Avg, Fiber Count per ML_______ 1.12 Hand sanding polyester furniture Power sanding boat hull 0.05 0.4 < 0.1 2.1 to 3 .0 < 0.1 2 .5 We, of course, recommend that you have your own operations surveyed by a qualified in dustrial hygienist to determine existing dust and fume levels. In this regard, we once again state our firm belief that if your facilities are ventilated to provide the required protection from dust and fume hazards for silica and styrene, that you w ill also meet the standards for The information set forth above is certainly not, and was not intended to be, an exhaustive analysts of present or proposed regulations and compliance procedures. We are w illin g , how ever, to meet with representatives of your company for the purpose of examining the presently applicable regulations and compliance procedures in detail. Very truly yours, JWR/es James W. Rawlings