Document MM489jRdBO2NBY4VpVMkeJdJV

rma! ASBESTOS INFORMATION ASSOCIATION >7?riii;/.<,i'-T-?.`yggssasa 1745 Jefferson Davis Highway, Crystal Square 4. Suite 503 Arlington. Virginia 22202 (703) 979-1150 31 July 1979 Mr. John P. DeKany Deputy Assistant Administrator for Chemical Control Environmental Protection Agency Office of Toxic Substances Washington, D.C. 20460 Dear Mr. DeKany: Pursuant to this Association's request of April 9 for infor mation concerning .your office's ongoing investigation of asbestos, a copy of a report entitled "Exposure to Asbestos" as prepared by the IIT Research Institute was made available to AIA/NA by your letter-of May 4. At a follow-on meeting on May 30 in EPA headquarters between EPA and AIA/NA repre sentatives the report was discussed, and written comments were invited to be forwarded. The Asbestos Information Association/North America is an incorporated, non-profit organization of 54 firms in the United States and Canada engaged in the mining/milling or sale of asbestos fiber and in the manufacture or processing of asbestos-containing products. AIA/NA is aware of the comments on the IITRI report that were submitted to EPA on June 15 by one of its member companies, the Johns-Manville Corporation. This Association strongly endorses J-M's comments and shares the same concerns regarding any credence that may be given the report as a part of EPA's investigation of asbestos. A copy of J-M's comments are enclosed for your ready reference and con venience . In addition, this Association has developed some general comments on the report as well as specific comments regarding alleged asbestos exposure from brake linings. These comments are attached and invited to your attention. At the meeting on May 30, a senior EPA official stated that the IIT Research Institute only had six weeks to prepare the study and referred to it as a "crude" report. A careful review of the report causes this Association to conclude that it is indeed a crude report and should be considered as having failed to meet its stated objective, i.e. "The purpose of the report is to gather the available information on asbestos sources and estimate the extent of the overall exposure to the general population." CAPCO JEN 0011124 Page 2 In view of the above, this Association requests that: a. The IITRI report not be used as a reference document in support of any rulemaking process undertaken by EPA. b. EPA clearly annotate the cover of the IITRI report with appropriate wording which directs specific attention to its shortcomings and deficiencies. The statement on page 1 of the report that "the present Exposure Index ranking is necessarily imprecise"could be overlooked in addition to being'an understatement of the report's lacking, in quality. c. No distribution of the IITRI report be made without attachment of J'Mft 's and AIA/NA comments thereto. Please know that this Association appreciates the opportunity to review and comment on the IITRI report. Sincerely, Executive Director Enclosures bjp/ws CAP CO JEN 0011125 Comments on TTTRI Report to HPA Entitled "lixposurc to Asbestos" Asbestos Information Association/North America General While the report states, "The present exposure index ranking is necessarily imprecise," precise conclusions are attempted. The report states, "Besides the technical and economical difficulty of measuring asbestos concentrations, two other facts of the hazard are,not clear." (1) "The attributes of asbestos that actually cause disease and which therefore can give reliable measures of exposure, and" (2) "the concentration and time period of exposure to asbestos that is hazardous." Despite this statement, definite conclusions are reached. The report states, "Exposure to asbestos in the work environment was estimated by assuming that in the primai'y industries, average exposure was 1.0 fibers per cc, 2.0 f/cc in secondary industries and 0.1 f/cc in the consumer industries. No criteria is presented for determining these classifications or ho.w an industry is rated as either a primary industry or a secondary industry. The statement is made, "These estimates suggest that the population exposure in the area surrounding manufacturing plants from waste disposal may be comparable to the population exposure to the occupational population." There is no data that would support the conclusion that people living around an asbestos waste disposal site are exposed to the same fiber concentrations as those persons who work within the manufacturin operation where the asbestos waste was generated. Brake Linings The statement is made, "Most of the exposure assessment effort for commercial use has been devoted to activities of high exposure levels such as installation and removal of insulation and vehicular brake lining servicing and replacement." Data accumulated regarding brake lining servicing and repair does indicate that there arc certain operations which are capable of producing excessive fiber concentrations if not performed properly. However, there is no preponderance of evidence which CAPCO JEN 0011126 2- indicates the entire operation produces "high exposure levels". In Table 7 :on page 29, the brake service and repair operations are shown io have a concentration of 0.8 fibers per cc. If this is in-.fact the case, the statement that brake lining service and repair is a "high exposure risk" would tend to be refuted. In the report there is a lengthy discussion regarding total brake emissions in New York City. The authors of the paper should refer to the F.PA report prepared by .Jacko et al which gives a definitive description of brake degradation products and their fate. CAP CO JEN 0011127