Document NErDxgzJ5NYrbBV9G0Gm8oayp

FILE NAME DuPont DUP DATE 1970 Sept 2 DOC DUP014 DOCUMENT DESCRIPTION Letter from James F. Morgan Industrial Hygiene Consultant DuPont to Robert O. Gorson Professor of Medical Physics Thomas Jefferson University -o, 9271 on 4 COA E. I. DU PONT DE NEMOURS & COMPANY . NEMOURS se WILMINGTON DELAWARE 19833 EMPLOYEE RELATIONS DEPARTMENT HASKELL LABORATORY TOXICOLOGY AND INDUSTRIAL MEDICINE CC NOMADUYS OL the hd lice on Spray Application of . Comr Asbe cc Jesse Lieberman Chief Occupational and Radiologi City Health Section City of Philadelphia . . ; A - 239 239 239 . September 2 1970 om 7 . Cc / . Robert O. Gorson Professor of Medical Physics Stein Center . Thomas Jefferson University 920 Chancellor St. 6 05 7 Philadelphia Pa Dear Professor Gorson EXHIBIT # Morgan 12 .DATE 10-23-86 7 MASTROIANNI & FORMAROLI INC ave _. i CERTIFIED SHORTHAND REPORTERS TE = In connection with my dissent to the of the members of the Ad Hoc Committee majority opinion _ Asbestos regarding regarding the draft on Spray Application of Fourth Meeting on August mit a memorandum 31 report that was discussed at the 1970 you have asked that I sub- expressing my views with on the Specific I wish to comment here- Recommendation A Asbestos Material page 7 and The Elimination of Spray upon which the recommendation on the preceding paragraphs is based . Paragraph 5 ensure page 4 points out that it is difficult to the spr1ay0i0ng coonptearianmteinotn of airborne asbesto. s material during This was established as Dr. Boucot after visiting the School and that of Mr. Wyman Association in a 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 health agency has put forth the intense nor any that is required to overcome a problem such as research this effort hygiene engineering has succeeded in devising Industrial procedures for safely processin angd using many potentially hazardous , such as beryllium uranium ore silica sand lead mercmuartyereitacl.s rial Methods without for spraying containing insulating mate- site emitting dangerous quantities of fibers from the can most certainly be devised provided sufficient time effort are expended by qualified engineering personnel and . . . R. O. Gorson Cont'd Page 2 . 240 September 2 1970 7 Similarly methods can be devised for the persons spraying containing insulating protection material of other persons working on the site and | example of a precedent for the during the spraying An safety procedures is afforded development of satisfactory in foundries metallurgical by sandblasting of metal parts yards etc. It establishments shipyards scrap helmets can now be done enclosures safely by using supplied developed for the and ventilation systems that have been purpose ; coat Similarly the procedures and regulations can be devised to sion sprayed into air insulation material and thereby prevent ero- supply ducts during maintenance With respect to health protection tion of structures wtohrek praelsteenrcaetioonf osfprstaryuectduraessbesotrosd-emoli- containing insulating material is only one part of the whole problem of dust dissemination of asbestos products These products may be encountered as pipe insulation as interior and exterior structural board and in floor tiles tion of sprayed insulating material The elimina- eliminate the need for an would 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 offer no recommendation which would Committee hinder adequate protection of the interfere with or hibition of the use of structure from fire A pro- would leave as containing material at this time 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 on a term basis with respect This concern for adequate protection of structures in 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 . 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 evidence furnished to the Committee that asbestos every other toxic agent can be tolerated at some than zero concentration without adverse response There was fibers like 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 : Acceptance of the statements made above the addition following parts 1 and 2 of this of a statement similar to the following would argue for recommendation unless the prospective prime contractor will furnish to the City of Philadelphia a detailed plan of procedure acceptable F to the City whereby emissions beyond the site will be con- trolled to the limits expressed in will give assurance that a sealant Recommendation C 2 coat will be applied and 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 : --"-- ------ -- James F. Morgan | Consultant Industrial Hygiene