Document MJvbOG1gM7MxL5QmwXwBMrx6M

FILE NAME Roofing ROOF DATE 1986 June 25 DOC ROOF003 DOCUMENT DESCRIPTION Letter from United Union of Roofers to the EPA RE Asbestos Proposed Mining and Import Restrictions United Union of Roofers WaterproofersWaterprofers Waterproofers and AlliedAllied WorWkoerrskers Office of the International President Earl J. Kruse Affiliated with AFL And Building and Construction Trades Department 1125 17th Street N.W. Washington D.C. 20035 638-3228 GE June 25 1986 Document Control Officer Office of Toxic Substances Environmental Protection Agency Room 209 401 M Street S.W. Washington DC 20460 RE Docket Control Number 62036 Asbestos Proposed Mining and Import Restrictions and Proposed Manufacturing Importation and Processing Prohibitions To The Document Control Officer The United Union of Roofers Waterproofers and Allied Workers which represents 30,000 commercial industrial and residential roofers and waterproofers in the United States supports the proposed ban and phase of all asbestos use in the United States Our primary concern is with installation and removal of exposure asbestos during the roofing felts But there are many contain asbestos other roofing products that still fibrous mastics and emulsions used in roof maintenance that have an asbestos newer fiber synthetic backing roofing membranes and asbestos shingles used largely in residential roofing Industry claims that asbestos fibers are locked or completely encapsulated in these products and therefore pose no health risk Some even claim that because the fibers are locked and no exposure is possible they are not as containing asbestos required to label those according to the Hazard products Communication Standard So workers and contractors end up in the dark once again about the products they're using We believe these claims aren't justified based on existing exposure asbestos data fiber What little evidence there is concerning release contradicts these industry assertions In the mid 1970s Manville conducted a series of air sampling tests to measure asbestos exposures on built- and up roofing installation roof removal projects report attached Following the NIOSH monitoring and analytical method P and CAM 239 the Manville study found exposures to be as high as 0.4f on roof projects involving the installation of asbestos roofing felts On roof removal jobs asbestos exposures were found to range as high as 1.7f According to OSHA's current standard for asbestos exposure 0.2f these exposures would be considered to present a significant health risk More recently the National Roofing Contractors Association has Two sponsored a study of asbestos exposures in roofing roofing sites were involved in this project One test site involved the installation of asbestos roofing felts the other was a roof removal project They found no detectable levels of asbestos fibers using either the revised NIOSH 7400 method or the P and CAM 239 method But there are major problems with their results using To achieve acceptable precision a minimum fiber loading of 100f the NIOSH of sampling must be produced None of the samples analyzed study appeared to meet this requirement 7400 method filter area in this Removing asbestos roofing shingles has also been found to release significant amounts of asbestos fibers The National Institute for Occupational Safety and Health NIOSH conducted an evaluation of asbestos exposures during the removal of an asbestos roofing shingle operation report attached NIOSH concluded from this study that a health hazard existed and recommended a combination of work practices and respiratory protection to reduce worker exposure to airborne asbestos fibers There is other objective data which demonstrate significant asbestos fiber release during the performance of built roofing work A study conducted by a student at Drexel University to fulfill requirements for a masters degree found significant airborne levels of asbestos fibers on two of three roof removal jobs tested On one jobsite personal exposures were found to be as high as 0.29f report attached It is clear that asbestos exposures occur in the process of installing industry's and removing asbestos roofing felts despite claims to the contrary The greatest potential for asbestos exposures occurs during the removal of asbestos felts when felts are scraped cut and chiseled using powered machinery It is also clear that asbestos exposures can vary from one roofing job to the next over a single work day and can vary greatly and unpredictably Even if the 8 hour TWA is low for some jobs there could be moments of brief intense exposures - There is evidence that these intermittent peak exposures which may predominate in our industry - can be dangerous and lead to asbestos related disease OSHA has pointed out that it is possible that intense exposures to asbestos may prove to be a variable independently related to asbestos- induced disease It appears are within from existing data that asbestos exposure levels boundaries that can be controlled using practical and economical methods like wetting the roof before and during the removal process and supplementing this work practice with respiratory protection While feasible solutions may exist they are seldom if ever used Respirators are not routinely provided on either installation or removal jobs When provided they are not used properly Workers are not Workers are not trained in how to use them tested and are not shown how to perform negative and positive pressure leak tests on the job No medical examinations are offered to respirator wearers to determine their ability to wear negative respirators And no roofing contractor to our knowledge has developed a written respirator program We find that in many cases roofers purchase their own respirators when they have been unable to get their contractors to provide them When they do it is usually a dust mask Although there are dust masks approved for low level asbestos exposure NIOSH does not recommend their use because asbestos is such a potent carcinogen Wetting the roof membrane before and during process may practice is significantly reduce exposures also not routinely done There where this practice is precluded the removal But this work may be situations Even with OSHA's newly promulgated asbestos standard there is no guarantee that contractors will follow the stricter requirements The reason is simple roofing jobs are virtually exempt from OSHA health inspections You would be hard pressed to find more than a handful of health inspections in the roofing industry in the past five years Inspections for asbestos exposures are almost existent Given OSHA's meager enforcement effort in the roofing industry and the lack of any effective controls being implemented on roofing jobs substitution is the only feasible way to eliminate the risk of asbestos diseases among our members We believe that safe and effective substitutes for asbestos products used in our industry do exist of the availability of substitutes aptly EPA's shows analysis that suitable alternatives exist for asbestos roofing felts The roofing industry has been moving away from asbestos roofing felts and other containing products As EPA indicates less than 10 of the roofing felts sold today contain asbestos We believe that all the evidence regarding asbestos strongly points to a ban on asbestos products as the only sure way of reducing the risk to workers and to society of asbestosrelated disease OSHA points out that even at the lowest feasible occupational limit 0.1f a significant risk of cancer still exists And it is the considered opinion of many experts that there is no safe level of asbestos exposure above the They conclude that any occupational exposure ambient air level represents some increased risk to the worker We believe that imposing a ban on asbestos roofing felts and other asbestos no economic burden roofing products on our industry would More pose than little or that such a ban will undoubtedly save lives Sincerely yours SincerelyKruse -- --,--...-- Earl J. International President csi attachments