Document NG1L63azkB5Mr5kYzYzr1JG4w

TECHNICAL COMMITTEE I > Lo Cu ... UCC 010857 ^4 f s~>-r?sr.*y-''x i* $L "ufSjzs&ssros UNION CARBIDE CORPORATION METALS DIVISION P.O.BOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 71G 278 337G July 26, 1976 Hr. Jarvis J. Gafford Director, Marketing Technical Services The Celotex Corporation 1500 North Dale Mabrey Tampa, FL 33607 RECEIVED JUL 2 8 1976 Dear Gerry: This is in response to your request for further information on the projected scheduling and activities of the A1A/NA Ad Hoc Committee for Construction. The latest information from OSilA is that Research Triangle Institute will receive the contract for the government's inflationary impact statement. Estimated completion time is six months but could be shortened considerably if the government decides to sacrifice quality for speed. A six month period calculates out to be about February 28, 1977. This study would be published by OSHA at the same time as a proposed rulemaking for construction with probably 45-60 days then allowed for comments. It seems prudent to plan at this time to target the completion of our study for the end of February, 1977 to allow some time for adjustments if they appear to be appropriate. While six months may seem like a long time, our past experience with Weston (and that of OSHA with Consad) shows that this type of study is si ow and difficult to put together. Accordingly we are currently trying to get the A1A/NA contractor selected and started by the early part of September. In order to do this I plan to have most of the subcommittee recruited and have our first meeting in Washington on August 12 and 13. The basic objectives of this meeting are attached. In order to have the information needed at this meeting several people and organizations have been asked to Dreoare the items in the "homework" listing also attached1. Based on past performance, the protocol for the government study is not likely to be too useful but we can always hope. The results of the subcommittee meeting would be worked up in more polished form for presentation to the Executive Committee in Washington on August 19. I would expect that you and I and a couple of other people we can press into service would scend some time on this between the 13th and 19th. It would probably be very desirable to get together in Washington on the 18th to get the presentation finalized. Assuming the Executive Committee agrees to proceed in accordance with our recommendations, we would be involved for a day or two in September UCC 010858 Mr. J. J. Gafford -2- July 26, 1976 making the final selection of the contractor and getting him started. Things would then lighten up until January to an occasional meeting with the consul tant to check on progress and make sure he was not straying. In January a detailed review and commentary on the draft of the report would be needed. As cochairman you would be a key figure in the organization of information and the decisions that must be made over the next six weeks while we get the consultant launched. I would also envision that the cochairman would serve as the primary contact with the consultant as the report is pre pared and would organize the detailed review of the draft. My own efforts together with certain other numbers of the subcommittee, would be directed towards the preparation of the other part of the package, i.e. the suggestions for the detailed wording in the regulations. I also expect to be heavily involved in preparation of the industry response in the hearings on the manu facturing standard. Hopefully this letter will provide the information you need to reach a decision on serving as cochairman, I think you can do an excellent job, and the industry needs help very urgently at this time. Sincerely, Harrison B. Rhodes Technology Manager HBR:dal Attachments CC: G. G. Gabriel son, Jr. R. H. Mereness ^ W. C. Thurber/ UCC 010859 MEETING OBJECTIVES AIA/NA Ad Hoc Committee for Construction Washington, D.C. (August 12 & 13 ?) 1. Select the approach to be used to relate the uses of asbestos-containing products with the statistical information available on the various com ponents of the construction industry. 2. Define in detail the asbestos-containing products to be covered. 3. Rough draft of protocol for AIA/NA consultant's study. 4. Rough draft of questionnaire for consultant to use to collect informa tion from the construction industry. 5. Discussion of consultants to be considered. UCC 010860 "HOMEWORK" FOR AD HOC COMMITTEE MEETING WASHINGTON, D.C. (August 12 & 13 ?) 1. Outline of A/C pipe applications with SIC code. (John McGinley ?) 2. Recommendations on the feasibility of U.S. government SIC codes and/or F.W. Dodge construction industry data as the source of detailed statis tical information on construction. Also recommendations on how asbestos use can be tred-in with this information. Gerry Gafford 3. Review of OSHA work protocol if available. (H. B. Rhodes) 4. Recommendations on consultants to be considered. (Guy Gabrielson) 5. Identification of all asbestos products to be considered with volumes, if possible. Commentary on use of SIC codes and F. W. Dodge data J/M Corporation. (Gerry, I plan to meet with them in Denver the week of August 2 to cover the same ground we did in Chicago and solicit their recommendation. There will be more emphasis on product identification.) UCC 01086! ASBESTOS INFORMATION ASSOCIATION 1335 K Stre^;. N.vV , Washington, D.C 20005 (202) 223-4S35 5 RECEIVED i. o' JUL 9 1976 23 June 1976 Memorandum To: H. B. Rhodes, Co-Chairman, Ad Hoc Committee for Construction From: G. G. Gabrielson, Jr., Chairman, Asbestos Regulation Task Force Subject Ad Hoc Committee Objectives As a consequence of discussions at the last meeting of the Executive Commitee of AIA, it is my belief that the Ad Hoc Committee for Construction; of which you have been appointed Co-Chairman, should have the following objectives: (1) Identify and define typical or representative * asbestos dust exposure situations in construction (including both personsworking with asbestos materials and others casually exposed to asbestos dust) and initiate the measurement and recording of TWA asbestos fiber exposures for all such situations. This task will require, of course, the development of data concerning the portion of the working day during which a typical or representative worker is exposed to asbestos fibers. (2) Develop a recommended protocol for a study, by an outside, independent consulting firm, of the technological feasibility and economic impact of whatever regulation OSHA may propose for the control of occupational exposures to asbestos in construction. I attach my own initial outline of such a protocol as a point of departure. (3) Recommend to the Task Force Chairman and to the Executive Committee a list of independent consulting firms qualified to undertake the study outlined in (2) above. (4) Based upon the general form and approach of the re gulation proposed Oct. 9, 1975 by OSHA for the regulation of occupational exposures to asbestos in manufacturing, prepare, section by section, the language of a construction industry regulation which AIA and cooperating companies and associations may wish to advocate in response to anvconstruction industry regulation which OSHA may proppstsT y { ^ ~~ cc: Executive Committee Gabrielson, Jr. an. Asbestos Regulation Task Force UCC 010862 Regulation of Exposure to Asbestos Fiber in Construction PROTOCOL FOR STUDY BY CONSULTING FIRM (1) List of asbestos containing materials used in construction. (2) List of applications for materials defined in (1) above. (3) Census of workers fabricating asbestos materials in con struction, dividing the total into trade or skill categories where appropriate. (4) Census of workers in construction casually exposed to airborne asbestos, dividing the total into trade or skill categories where appropriate. (5) Distribution of numbers obtained in (3) and (4) above into defined oeriods of time employed in construction (i.e., what portion, during their lifetimes, will work in construction 0-5 years, 5-10 years, 10-15 year, etc.) (6) Distribution of numbers obtained in (3) and (4) above into defined periods of average daily exposure to asbestos (i.e. what portion, during a normal work day, will be exposed to airborne asbestos 0-1 hour, 1-2 hours, 2-3 hours, etc.) (7) Cost per exposed person of mandated medical surveillance and total annual cost for the construction industry (derive number of annual physicals from the proposed regulation and (3) and (4) above and multiply by the medical surveillance cost per person). (8) Cost per exposed person of mandated industrial hygiene facilities or procedures (i.e. protective clothing, respirators, showers, change rooms, etc.) and total annual cost for the construction industry. (9) Typical dust count data for each category in (3) and (4) above. 1 (10) Definition of engineering controls available for the different categories of tools and operations used in the fabrication and installation of asbestos materials in con struction and dust counts which may be achieved.11 (11) Potential availability of engineering controls defined in (10) above. ( At least one power tool manufacturer has decided that the potential market is too small to develop, introduce and sell tools with standard dust control attach ments .) UCC 010863 Page 2 (12) Feasibility (including economic feasibility) of engineering controls in construction. (13) Data, if available, indicating transient nature of con struction workforce. (14) Feasibility of any proposed medical surveillance or recordkeeping program in light of transient character of workforce. (15) Distribution of construction activity into categories by dollar magnitude of individual projects. (16) Percentage increase in construction cost of each category defined in (15) above which would result from compliance with proposed regulation. (17) Extent to which asbestos materials defined in (1) above would be displaced by non-asbestos materials as a conse quence of implementation of proposed regulation. UCC 010864 ASBESTOS INFORMATION ASSOCIATION / it'nf U 26 December 1973 cA Mr. William C. Thurber Union Carbide Corporation 2 70 Park Avenue 38th Floor New York, New York 10017 jrj Dear Bill: We were pleased to receive your nomination of Dr. H. B. Rhodes to serve on the Association's Technical Committee. As you will recall from our memorandum of November 30th, Ed Fenner of Johns-Manville will serve as Chairman of the Committee. A first order of business is for a task group of the Committee to meet with OSHA people. An appointment has been made for this purpose on January 10th. Ed Fenner, Ike Weaver of Raybestos-Manhattan, and Harold Becker of Nicolet will participate in this meeting. Shortly after ward, a meeting of the entire Committee will be called to define immediate and long range tasks, procedures, commun ications, etc.. Ed will be in contact with your representa tive in the near future for this and other related matters. The coming year will bring increased demands on the asbestos industry to deal with problems related to health and work place conditions. We are fortunate to have outstanding personnel available to the Association to address themselves to the technical aspects of these problems and appreciate your personal cooperation in the important work of the Association's Technical Committee. Co R. H. Mereness Executive Director RHM/cg ^fc.Cfc.1 vtu DEC 2 7 1973 UCC 010865 20, 1973 hAt Robert H# AAosonoss, Dtpp^or AsbsWos information AaodaHa^iailli Aamrlca 1660 L. Shoot, N.W. Washington, D. C. 20036 Door lob: In npljr to poor lottor af November 30, 1973, roqwacting nominations for tbs nawty croatod Technical Cammlttoo, f am ptmssd to nemlnato Dr. H. ft. thedas to servo on tills Cooasittoa. fty wo/ of background. Dr. tliadas rocoivod tils ftS in 1948, Ms MS in 1949 and Us PhD in Chemical Enginewing from Colinnbla Uiimnity in 1960. Ho was in ftftD idHi San Oil Company from 1949 - 1953 and from 1954 - 1957 woricad In Hw Colombia University Mlnarol Banofieiation lab. Ho starlad with Union Carbido tn 1957 and spant Ion poors In Molocolar Sieve ftadwcts in fcftD, onglnoorlng and marketing copodHos. Ho foinod tbo asbostos RID group In 1968and ocooptod aaofcaHng and solos responsibilitlos In 1970. Ha has partidpotod in most af Union Carbide's tospensos to proposod legislative actions and similar manors and amlnSains a coaHmsaas ravlaw of acHvitios bp OSHA, EPA, FDA and other agendas. Ho is rosponsfhlo far tbo air sampling sorvlco wo provide to amtoamrs and alftmr aspects Involving dost sMoitaring and tooting. Ho spends a largo poreoajpsga af his time In the Bold with ewstomars and this typo af WCT:as Vary holy yawn. W. C. Tbasfaor UCC 010866 UC US`-2 UNION CARBIDE INTERNAL CORRESPONDENCE MINING AND METALS DIVISION To 'Name) Mr. W. C. Thurber Division Mining and Metals Location t\lew York, NY copy to r, e. Byrne H. B. Rhodes P. 0. BOX 579, NIAGARA FALLS, NEW YORK 14302 Date Originating Dept. Answering letter date Subject December II, 1973 "Calidria" Asbestos - Marketing AIA Technical Committee Per our prior discussion please nominate H. B. Rhodes for the Subject. Hajccy received his BS in 1948, his MS in 1949 and his PhD in Chemical Engineering from Columbia University in I960. He was in R & D with Sun Oil Company from 1949-1953 and from 1954-- J957 worked in the Columbia University Mineral Beneficiation Lab. He started with Union Carbide in 1957 and spent ten years in Molecular Sieve Products in R & D, engineering and marketing capacities. joined the asbestos R & D group in 1968 and accepted marketing and sales responsibilities in 1970. He has participated in most of^Carbide's responses to proposed legislative actions and similar matters and maintains a continuous review of activities by OSHA, EPA, FDA and other agencies. He is responsible for the air sampling service we provide to customers and other aspects involving dust monitoring and testing. Harry spends a large percentage of his time in the field with customers and this type of experience should be valuable input to the committee. V Myers r^. /ds UCC 010867 KfcCErfVED DEC 1 3 1973 i ASBESTOS INFORMATION ASSOCIATION y 30 November 1973 Memorandum For: MEMBERS Subject: Establishment of AIA/NA Technical Committee Increased activity on Federal, State, and private levels regarding the asbestos-health issue has resulted in accelerated demands upon the Association for both initia tive and responsive actions on behalf of the asbestos industry. To meet these demands -- for example, develop ment of revised OSHA standards, answers to technical queries, etc.,--a Technical Committee is proposed to be constituted and in operation as soon as possible. The Committee will be called upon to provide technical in formation and guidance to the AIA/NA president and executive director for the conduct of Association work in keeping with the wishes of its directors. The Committee will consist of 5 to 9 persons, depending upon the availability of qualified personnel to serve. A working group will be designated to meet with OSHA representatives for consideration of revised standards and to meet with such other agencies as may be required. An organizational meeting will be called at the earliest date practicable. It is planned that the working group will meet with OSHA people the first week of January. I am pleased to advise you that Ed_ Fenner^_of_jJqhnsj^Manvi.lle has agreed to serve as chairman ofthe Committee. It is requested that each director consider nominating a person from his organization to fill out the Committee membership. The person's name and a brief resume of his educational and work background are desired, if possible, at the time of the Board of Directors meeting December 6. General qualifications for Committee membership are described in the attachment. It is not expected that in ordinate demands will be placed on any Committee member's UCC 010868 2 Establishment of AIA/NA Technical Committee time, although availability for meetings at the seat of government, from time to time, will be essential to the conduct of Committee business. It is understandable that some members may not be able to nominate a person for the Committee. Negative responses are requested. Members may be sure that the interests of the entire industry will key all deliberations of the Committee, and all major proposals of the Committee will be subject to review of the Association's directors. Your cooperation and early response are appreciated. R. H. Mereness Executive Director Attachment UCC 010869 SUGGESTED QUALIFICATIONS FOR AIA/NA TECHNICAL COMMITTEE (1) Education: Bachelor of Science degree (or equivalent) in one of the engineering disciplines. (2) Background: Individuals should currently be responsible for one or more of the following: a. Compliance with OSHA Asbestos Standards within a company or individual plant. b. Safety and health within a company or individual plant, including Industrial Hygiene monitoring. c. Design and construction of equipment required for compliance with OSHA Asbestos Standards. UCC 010870 AW ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660 L Street, N W , Washington, D C. 20036 (202) 223-4885 y 24 May 1976 RECEIVED may 2 6 197b Memorandum For: STANDARDS AND TECHNICAL COMMITTEE Subject: Change in Washington, D.C. feting from June 3-4 to June 23-24 Since my letter of May 11 setting the above noted meeting, OSHA has scheduled a very important Construction Industry Asbestos Sub-Committee hearing in San Diego on June 2-3. It is anticipated that several of our members will be participating in this hearing and several others have conflicts that cannot be shifted. In view of this it seems best to reschedule our meeting for June 23 and 24 at the new AIA/NA office at 1835 K Street. We will proceed at 8:30 a.m. on the 17th with those present. This change has been made with great reluctance and we hope it does not cause you too much inconvenience. Because of the great influx of tourists in Washington, please advise Bob Mereness as soon as possible whether you will attend and what accomodations you will need. y- 4. fULrcb, H. B. Rhodes Chairman Standards and Technical Committee HBR:dal CC: Messrs T. A. Dougherty G. G. Gabrielson, Jr. R. H. Mereness W. C. Thurber-'^ UCC 010871 ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660 L Street, N.W. / Washington. D.C. 20036 / (202) 223-4885 11 May 1976 Memorandum For: STANDARDS AND TECHNICAL COMMITTEE Subject: Meeting June 3-4, Washington, D.C. Now that everyone has had time to recover from the rush to meet the April 9 OSHA deadline, we need to get our committee back into action. Accordingly, a meeting is called in Washington, D.C. on June 3 and 4. A preliminary agenda is attached. If you have any other suggestions, please let me know. There appears to be too much to cover effectively in one day so two days have been scheduled. We plan to start at 9:30 a.m. on Thursday, June 3, to mini mize the number of people who will have to fly in the night before. We will wrap up by about 3:00 p.m. on Friday. The meeting will be held at the AIA/NA office. I expect to be traveling most of the next two weeks so it would be appreciated if you will let Bob Mereness know as soon as possible if you can attend. He will be glad to make any hotel accomodations needed. The OSHA Hearings will be upon us very soon and it is obviously important that we do not wait any longer to get organized. I hope you will make every effort to attend. H. B. Rhodes Chairman Standards and Technical Committee HBR:dal Attach. CC: Messrs. T. A. Dougherty G. G. Gabrielson, Jr. R. H. Mereness s W. C. Thurber' UCC 010872 PRELIMINARY AGENDA AIA/NA STANDARDS AND TECHNICAL COMMITTEE MEETING Washington, D.C., June 3-4, 1976 1.. Preparation for the Coming OSHA Hearings. As you know, the committee made a substantial contribution to the industry written presentation. We need to determine what further input is needed and organize to provide it. 2. Report on Mesa Activities. Mesa has recently made some moves that may have severe impact on a number of the member companies. Mr. Frank Zimmerman will make a brief report. 3. Technical Discussion on Monitoring Procedures. Several of the OSHA presentations raised serious questions regarding the validity of the NIOSH monitoring procedure, particularly as it applied to levels around 0.5 fiber/cc. The J/M presentation, which you should have, is particularly noteworthy in this regard. We need to review the evidence and suggest a definitive industry position to the Executive Committee. Please be prepared to discuss this problem and/or present your company's recommendations. 4. Preparation of a Technical Information Package. ' The AIA/NA is receiving daily requests for specific infor mation on dust control equipment, masks and respiratory protection programs, protective clothing and monitoring. We need to put together a comprehensive information package on these subjects including lists showing where the materials and services can be purchased. It is planned to settle on the format of this package and appoint a small group to assemble the facts and draft it. Please bring all of the information you feel should be included to the meeting. This portion of our meeting will be a working session. 5. Consideration of an Employee Information Program Package. There is no question that some sort of employee training program will be included in the new OSHA regulations. There is also a need right now for the same kind of information. We want to examine what the various number companies now have available, whether an AIA/NA program is appropriate, _ and if so, where it should fit into our activities. In this connection the new J/M employee presentation film "Working With Asbestos" will be shown. UCC 010873 ASBESTOS INFORMATION ASSOCIATION NORTH AM6ACA I860 L Street. N.W. / Wellington. O.C. 20036 / (202) 2234885 23 February 1976 Memorandum For: Standards and Technical Committee Subject: Change in Committee Membership This is to advise that Nicolet's member on the AIA/NA Standards and Technical Committee has been changed from Mr. C. Craig Wilson to Mr. A. M. Callahan. A current listing of committee members is attached. tv ///# / R. TT/ Sereness y `Executive Director Enclosure >/ cc: Mr. William C. Thurber, Union Carbide, Standards & Technical Chairman UCC 010874 ...' --hOa.: \ Vv List IB - STANDARDS & TECHNICAL COMMITTEE (12) Edmund M. Fenner Director Environmental Services HS & E Department Johns-Manville Corporation Greenwood Plaza Denver, Colorado 82017 (303) 770-1000 William Fassuliotis Director Safety & Security GAF Corporation 140 West 51st Street New York, N. Y. 10020 (212) 582-7600 Stanford K. Christian Industrial Hygienist The Bendix Corporation Bendix Center - Executive Offices Southfield, Michigan 48075 (313) 352-5372 John P. McGinley Director Mfg. A/C Pipe Certain-teed Products Corporation P. O. Box 860 Valley Forge, Pennsylvania 19482 (215) 687-5000 William H. Mortonson General Manufacturing Manager The Flintkote Company 480 Central Avenue East Rutherford, New Jersey 07073 (201) 438-2800 Sudhakar Dixit Manager Garlock, Inc. Division Street Palmyra, New York (315) 597-4811 14522 Fraser Morton Congoleum Industries, Inc. Cedarhurst Plant Finksburg, Maryland 21048 A. M. Callahan Corporate Engineering Nicolet Inc. Wissahickon Avenue Ambler, Pennsylvania (215) 646-4000 Manager 19002 Frank Zimmerman Corp. Director Safety & Environmental Health National Gypsum Company 325 Delaware Avenue Buffalo, New York 14202 (716) 852-5880 Isaac H. Weaver Director Environmental Control Raybestos-Manhattan, Inc. 123 E. Stievel Street Manheim, Pennsylvania 17545 (717) 665-2706 Dr. H. B. Rhodes (Chairman) Area Manager Marketing & Tech. Union Carbide Corporation P. 0. Box 579 Niagara Falls, New York 14302 (716) 278-3375 G. J. Hildebrandt Senior Research Associate Jim Walter Research Corp. 10301 Ninth St. North St. Petersburg, FL 33702 (813) 576-4171 x 230 UCC 010875 m ASBESTOS INFORMATION AS NORTH AMERICA 1660 L Street N.W Washingj^n. D C 20036^(202) 223-4 KECEiveo ApK 1 9 1976 14 April 1976 Memorandum For: Mr^floel W^-Hendry, Johns-Manville Corp. 'Ison B. Rhodes, Chairman, Standards & Technical Committee Subject: Inquiry Chesterton Packings & Seals, April 1, 1976 Your assistance in review and comment on subject letter, attached, for preparation of reply from this office is requested. A number of similar inquiries have been answered by direct re ference to the OSHA standard and to publications available from this office. This has been a satisfactory procedure; however, in view of growing concerns by industry's customers regarding asbestos-containing products, your thoughts as to the Association's response to Chesterton and letters of similar nature will be most helpful. R. H. Meretfess Executive Director Enclosure cc: Executive Committee UCC 010876 CHESTERTON PACKINGS and SEALS A. W. CHESTERTON COMPANY MIDDLESEX INDUSTRIAL PARK - ROUTE 93 STONEHAM, MASSACHUSETTS 02180 U. S. A. AUE^CA'S OLDEST CHESTERTON WOULD S FINEST EST 1884 Tel. Area Code 617 438-7000 Cable Address CHESTERTON S TON E HAM, MASS. Telex Number 94 941 7 April 1, 1976 ASBESTOS INFORMATION ASSOCIATION 1660 L Street NW Washington, DC 20036 Attention: Mr. R. H. Mereness Executive Director Dear Mr. Mereness: The A. W. Chesterton Company is a manufacturer of mechanical pack ings and seals and our primary market area is the chemical process industry. Many of our products contain asbestos, and we were actively involved in the recent Washington meetings and with the Western survey. We are members of the Fluid Sealing Association. We are receiving more and more requests from industry along the lines of "Do your products comply with 0SHA regulations regarding the han dling and use of asbestos containing products?" We would like to have a uniform answer to this request and, quite frankly, are at somewhat of a loss as to how to do this. In the mechanical packing industry, virtually all of the products which contain asbestos do so with it in a locked-in form such as as bestos in sheet packing and asbestos in mechanical braided packings which are always saturated with lubricants and greases of some sort. With that in mind could we make a statement to industry in answer to this question as follows: "The products of our manufacture which contain asbestos fi bers have been modified by a bonding agent, coating, binder, or other materials so that during any reasonably foresee able use, handling, storage, disposal, processing, or trans portation, no airborne concentrations of asbestos fibers in excess of exposure limits as defined by 0SHA would be re leased. There is no foreseeable use of our products which would create any measurable amount of asbestos airborne par ticulate matter. If it is necessary to alter these materi als in your plant, they should never be sawed or abrasive cut in any way but should, in fact, be cut by a knife-type ac tion ." UCC 010877 - page two Quite frankly, that is the way we see this matter but do not wish to proceed with this statement until someone such as yourself has commented on it; and, thus, you have the purpose for us writing this letter. We would, of course, be very anxious to seek an alternative state ment and perhaps the least troublesome approach would be to have each industrial company that writes to us refer to the appropriate regulations themselves. My personal feeling is that this is im practical as the great majority of users of these products will have no method by which to measure asbestos airborne contents. It appears to us that we walked the fine line between creating a condition where the customer won't bother to use asbestos products and defining the OSHA regulations. May we please have your thoughts on this. Very truly yours. RH:jrv cc: R. T. McDermott UCC 010878 ASBESTOS INFORMATION ASSOCIATION 13 February 1976 V ^CNVED FEb o 19/6 Mr. Joseph C. Jacksor Executive Director Asbestos Cement Pipe Producers 1875 Conn. Ave., N.W. "Washington, D. C. 2( 009 / Association" ' Dear Joe: Enclosed please find a set of recommended work place practices developed by our Standards and Technical Committee. These book lets are now being widely distributed within pertinent segments of the industry. We have had inquiry as to a recommended work practice booklet for asbestos-cement pipe. You will recall that we had planned to de velop such a booklet. Later we were advised that it would be un necessary for AIA/NA to perform this work. I believe ACPPA might wish to review its position in view of the work being done by AIA/NA for all segments of the asbestos industry in the area of occupational health. It would seem prudent for several reasons to now proceed and we shall be happy to do so. As you can see from the enclosures, production would simply require a change in cover design and tailoring of the sections ''products and operations" and "specific recommendations." The balance of the booklet is ready for printing. Our Standards and Technical Com mittee is prepared to move on this project with all haste. We would appreciate a "go ahead" and an indication of quantity re required. We would, of course, offer the copy for your review. The booklets can be made available at production cost of $1.35 each, with a run of 2,000. We would affect such distribution as you direct. Please let us hear from you at your earliest convenience. I believe your directors will concur in the timeliness of this project. With all good wishes, R. H. Mereness Executive Director cc: Mr. Dougherty RHM: v Enel:5 bec: Mr. Hendry, Mr. Thurber, Dr Rhodes Beasley, Mr. Barge, Mr Hooker UCC 010879 4 ASBESTOS INFORMATION ASSOCIATION-- 18 February 1976 Mr. Brent Farber Secretary Fluid Sealing Association 2017 Walnut St. Philadelphia, PA 19103 Dear Brent: Following on our conversation c In our original plan we had in mind publication of recommended work practices in each of the sub areas of the asbestos industry including "packings, gaskets and sealing devices." Five of these booklets are now in print as you may see from the enclosures. On the basis of interest we would like to proceed with a work practice for "packing gaskets and sealing devices." The job would be simple enough, that is we would design a cover and tailor the sections "products and operations" and "specific recommendations." Our Standards and Technical Committee with people like Ed Fenner of J-M and Bal Dixit of Garlock can pre pare the material. The balance of the booklet is applicable throughout the industry. Could you advise of your interest in proceeding with this project and how many booklets you estimate would satisfy your members and associates? The booklets would be available at production cost of $1.35 each on the basis of a 2,000 run. We would affect such distribution as you direct. I look forward to hearing from you at your earliest convenience. With all good wishes, Co] '' ' n R. H. Mereness Executive Director / cc: Thomas A. Dougherty,^William Thurber H. D. Rhodes, Ed Fenner, Bal Dixit Enclosure RHM: v UCC 010880 11 February 1976 RECEIVED Ft 8 1 3 1976 / Memorandum For: Subject: Reference: Dr. Rl^odes,-Chairman,standards and Technical Committee ..... " " __ Technical Information Program'' ""-- -- Letter 1/29/76 Abel Jacob Savage, Bendix Corp. Attached correspondence is forwarded for comment. As you know, we have considered distribution of a continuing series of "technical bulletins" for the information of members concerning equipment and processes for monitoring, dust control, personal equipment, etc. The enclosure, in response to my query to Bendix, is pertinent. I wonder if the Standards and Technical Committee should consider the scope of such a program and develop the information necessary thereto. Perhaps a subcommittee for this purpose might be in order. I would appreciate your thoughts and recommendation^. / 5/^- j R. H. Mereness Executive Director i ,` , 1 cc: Executive Committee \^/encl. Enclosures RHM: v UCC 010881 Memorandum Fo Subject: _ concerning proposed revision to OSHA asbestos standard This memorandum is hurried to you as a follow-up to our meeting of November 20 in Arlington, Virginia. I met with the Association's Executive Committee on November 21 and reported on the work we accomplished and what we proposed to do in support of AlA/NA's response to OSHA's proposed revision to the asbestos standard. The Executive Committee concurred in our basic approach to the problem. Members are, therefore, requested to commence immediately an in-depth study of the engineering-technological feasibility and economic impact of the proposed standard re vision within respective companies for the segment of the in dustry assigned at our meeting. In addition, and as discussed, we should commence preparation of responses to the 16 major issues enumerated in the preamble of the proposed revision. It is also suggested that we commence through our marketing organizations to build a profile of asbestos-containing products and users. For obvious reasons, any contacts made outside our own companies must be addressed to the specific issues of the pro posed standard. Data which relates to competitive activities is in no way involved in the descriptive information we wish to develop for the overall industry picture. A count on the number of exposure locations, approximate exposure levels, and number of people involved should serve our purposes. The Executive Committee has under consideration expansion of present capabilities of the AIA/NA task force by engaging the services of a consultant to coordinate the completion of industry data. The Committee has in mind perhaps a retired person with extensive industry background and other appropriate qualifications.I I know that many of you are working with trade associations from which general information pertinent to our assignment may be acquired. Bob Mereness is preparing a letter to all applicable associations. UCC 010882 Page 2 Below is an outline of what we discussed at the meeting and what we must proceed to do with all haste. As we get going a clearer picture will present. We will be kept advised of all deliberations of the AIA/NA task force. I have been invited to the meeting of directors on Dec. 11. As of this time all target dates apply. We do not know as yet concerning the request to OSHA for an extension. 1. General a. The objective is to achieve a logical, orderly and reasonable profile of the situation in each segment of the asbestos industry. b. Assumptions and exercise of best judgement will be required. Make clear where assumptions have been made and what they are. c. The present and proposed standards must be compared. There are parts in the proposal that we know are unclear. In terpret to the best of your ability and state the interpretation used. d. The plan is to break each segment of industry down into a series of representative steps starting from the boxcar of asbestos to the finished product in place via the final user. In some cases where several basic processing sequences are used they must be looked at separately. The steps where exposure occurs should be analyzed for control costs. The overall picture for the industry segment will be built up by multiplication for the number of times each cost factor occurs. This approach has the key advantage that once the cost components are identified and catalogued the first order effects of changing component costs or eliminating certain requirements can be cal culated fairly easily. 2. Suggested Procedure1 a. Define clearly the industry segment being studied in cluding: (1) Identification of sub-industry (2) No. of companies and plants (3) Number of asbestos-related employees broken down by: UCC 010883 Page 3 (i) Total employees on site (ii) Percent with regular exposure (operators, maintenance mechanics, etc.) (iii) Percent with probable or possible occasional exposure (iv) Percent with probable no exposure (4)Block diagram describing industry from freight car of asbestos through user including distribution chain. (5)Describe competitive products of the sub-industry. b. Start with your own company as the situation now exists. (1)Identify points on the block diagram where dust exposure occurs, describe the controls now used, levels reached, costs of operation, and investment costs. Also identify the people exposed in the three categories noted vis: (i) Percent with regular exposure (operators, maintenance mechanics, etc.) (ii) Percent with probable or possible occasional exposure (iii) Percent with probably no exposure This should be done at each exposure point. (2) Look to the best available dust control technology. Define what the technology is, the level attained (If already installed) or the level expected, cost to install, timing to install, power requirements and operating costs. Such items as bulk handling equip ment and storage, automatic bag openers, wet cutters, etc., in addition to mechanical ventilation, should be identified. Define decreases in production brought about by equipments. (3) If the best available technology is not expected to achieve 0.5 fiber/cc apply some speculative judgment on what approach.or approaches might be tried to 0.5 fiber with corresponding timing and cost. UCC 010884 Page 4 (4) From the number of locations and the number of people involved estimate the additional com pliance costs, i.e. those generated in addition to dust control equipment, for the other parts of current and proposed regulation. Check list: (i) Monitoring (ii) Medical examinations (iii) Record keeping (iv) Disposable or work clothing (v) Special waste disposal procedures (vi) Capital for special locker rooms, showers (vii) Employee training programs (5) Put together the same picture as things existed in June, 1972 prior to enactment of the OSHA regulations. I welcome your comments and deeply appreciate your cooperation in the onerous task before us. I shall stay in touch as new developments and changes occur. Z7-, Z'j-j H. B. Rhodes Chairman, AIA/NA Standards & Technical Committee Enclosure cc: Executive Director, AIA/NA W. C. Thurber, Union Carbide, Standards & Technical Chairman HBR:vld UCC 010885 asbestos standard. The enclosed correspondence from EMV Associates, Inc. is invited to your attention. We will keep the Committee apprised of formal objections to the standard on technological and engineering basis as information becomes available to us. R. H. Mereness Executive Director cc: Mr. Thomas Dougherty Mr. Guy Gabrielson Mr. William Thurber RHM:vld UCC 010886 EMV ASSOCIATES'* MICROANALYSIS LABORATORY 15825 SHADY GROVE ROAD ROCKVILLE, MARYLAND 20850 (301) 948-7400 November 19, 1975 Mr. R. H. Mereness Asbestos Information Association 1660 L Street N.W. Washington, D.C. 20036 Dear Mr. Mereness: In response to our phone conversation, a copy of our statement to the Government on the QSHA asbestos standard is enclosed. While this statement may appear self-serving in that it suggests replace ment of the 400X light microscope method for detecting 5 u fibers with electron microscope and x-ray analysis methods, it is, nevertheless, fully justifiable. As an independent, privately-owned analytical laboratory, we have no axe to grind on such matters as asbestos standards, other than what consti tutes adequate, cost effective technology. The QSHA method is technically inadequate, while, on the other hand, thej?Q$|f/Ssion EM approach methods at $200 and up per sample are not cosj We have consistently maintained lama i&HHaipy demonstrated that the scan ning EM provides an optimal capahHlrt3M*or effective analysis with lower sample cost ($50 each in quantityTwith reliable identification of asbes tos in samples contaminated by other non-asbestos fibers. From the viewpoint of the asbestos Industry, the OSHA standard is unfair because it does not identify fibers as being asbestos. For example, we have analyzed samples for EPA where only one fiber in 100 which resembled asbestos was actually asbestos by x-ray analysis. It would be exceedingly unjust for your members to be penalized or even put out of operation by a standard which may bear little or no relationship to an actual danger to workers. Such a non-specific method does not stand scientific scrutiny. On the other hand, the high cost of fiber counting and measurement studies, if used to an extent necessary to provide effective monitoring, would be prohibitively expensive. Automated image analysis methods such as one being developed at Penn State are not yet adequate to analyze actual sam ples because of complications in size range, non-asbestos contamination, and inadequate availability. UCC 010887 We are available to the asbestos industries for the performance of rapid, reliable, economical and fully confidential analysis of asbestos samples collected on filters. Such services are available to the extent needed to be practically utilized. Sincerely, ^ James H. McAlear, Ph.D. President UCC 010888 EMV ASSOCIATES ,wc C-'C/.lABCRATC. i-:;p2s sha:;v crgv pc---: rcckvcll. var ;3c:' 343-7400 November 4, 1975 Docket Officer Docket H-033 U.S. Department of Labor Room N-3620 200 Constitution Avenue N.W. Washington, D.C. 20210 OBJECTIONS TO PROPOSED RULES ON OCCUPATIONAL EXPOSURE TO ASBESTOS PART II, FEDERAL REGISTER, October 9, 1975 Objector: James Harvey McAlear, Ph.D., President EMV Associates, Inc. 15825 Shady Grove Road, Rockville, Maryland 20850 Objections to: 19 10.1001 (e) Monitoring (3) Method of measurement All determinations of airborne asbestos shall be made by the membrane filter method at 400-500X magnification (4ntn objective with phase contrast illumination). Objection: #1. The optical resolution of the proposed method is inadequate to per ceive the much larger nunber of asbestos fibers hazardous to health cer tain to be present in air. In the optical system specified by 0SHA at 400-450 the resolution is approximately one micrometer. Asbestos (chrysotile) may have a unit fiber diameter of only 0.025 micrometers. #2. The OSHA method does not distinguish between asbestos and non-asbestos fibers. In phase contrast optical illumination small fibers of animal and vegetable origin resemble asbestos fibers. Such fibers are frequently found in much greater numbers than asbestos. #3. The OSHA method is unenforceable if it cannot specify that the fibers measured and counted are asbestos. It is unfair to manufacturers because it "penalizes for non-asbestos fibers." Actual asbestos may be less than 1% of such fibers. #4. The OSHA method is not relevant to health hazards. In that it detects only those fibers which are so long as to be removed by the natural fil tering mechanisms of the nose and throat, the method must assume a close relationship to the much larger number of uncounted fibers below 5jt^(10Q to lO.OOOX) in most cases. The error is so large that the light optics UCC 010889 estimation Is not statistically significant in terms of the actual number of hazardous fibers. The OSHA method does not protect workers. #5. Improved technology Is readily available and is used extensively by other agencies. Two methods involving electron microscopy are routinely used which can visualize the smallest fibers and can generally distinguish asbestos from organic fibers. Of these methods the one using the scanning electron microscope involves little more specimen preparation than the OSHA method. The method has been extensively evaluated by FDA and EPA in government and private laboratories at government expense and is regularly used by them for reasons similar to OSHA. A typical scanning electron microscope evaluation involves: filtering air with a large (8jt0 nuclemore filter, followed by a small (0l2>l0 filter. The second filter is vacuum coated with gold palladium to make It conductive and the samples examined at 1,000X, then 10,000X, and the frequency of fibers showing x-ray fluorescence characteristic of asbes tos are estimated against standards. Examination time is less than 30 minutes. UCC 010890 ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660'fc'Slreet. N.W / Washington. D C 20036 / (202) 223^885 T* \\ Received \ SEP 2 4 1974 WASHINGTON, D.C. A meeting of the full Standards and Technical Committee was held in the Army-Navy Club in Washington, D.C. on September 10, 1974. Items discussed are listed on an attached copy of the agenda. Action taken on these items is as follows: (1) After thorough review of the AIA/NA submittal to OSHA it was the Committee's opinion that certain ' items in this submittal could be revised for clarification. R. H. Mereness suggested that before written clarification was submitted, it be discussed with Harry Gilbert, OSHA Project Officer for the Asbestos Standard. Mr. Mereness arranged for Mr. Gilbert to join our meeting after lunch. After review of all items in our recommended revisions with Mr. Gilbert, it was decided that it would not be necessary for the AIA to submit written clarification, since Mr. Gilbert understood our aims. Mr. Gilbert spoke at the two-day industry-government conference sponsored by the AIA and during his presentation mentioned OSHA1s'timetable. They expect that a revised draft of the Standard will be on the Solicitor General's desk for review by November 1, 1974. The proposed Standard after review will be published in the Federal Register in early 1975. This will be followed by time for written comments and a public ` hearing with verbal testimony. They anticipate that / the final revised Standard will be promulgated in /, June 1975. Iy UCC 010891 cx a f/\ 's I. /[/v ^ iiA A- 4 . i f( S;J< AIA STANDARDS AND TECHNICAL COMMITTEE PAGE 2 SEPTEMBER 17, 1974 (2a) California Senate Bill 2419 banning the spray of asbestos-containing material after July 1, 1976 was proposed by California State Senator Marks. Apparently, a number of letters have been addressed to Senator Marks' office commenting that there are certain asbestos-containing materials that can be sprayed on buildings and structures without releasing, from a health standpoint, significant quantities of asbestos fiber. Senator Marks' office indicated that if data to prove this contention were submitted to his office, he would consider amendments exempting these materials from the regulation. Johns-Manville and Union Carbide will arrange through their respective fiber customers to obtain data on concentrations of airborne fibers generated during certain specific spraying operations. This data and suggested wording for an amendment will be submitted by AIA to Senator Marks' office in December 1974. (2b) It was agreed that H. B. Rhodes and E. M. Fenner would comment to R. H. Mereness on significant omissions in the California State Department of Health paper "Asbestos in the California Environment". Mr. Mereness, as Executive Director of AIA, would forward these comments to the author of the paper. `' (2c) No action was taken during the Committee meeting. (3) A major portion of the meeting was devoted to a discussion of preparation of work practices documents for AIA/NA member company customers who purchase asbestos-containing products. Decisions as to work practices and assignment of one or mo-re members of the Committee to be responsible follows. All.work practices will include description of the '* pertinent part of the OSHA Asbestos Standard and recommended procedures for handling, fabrication and installation of the particular material involved.1 2 3 4 5 (1) Friction materials - (Weaver, Clark) (2) Asbestos textiles - (Moody, Weaver) (3) Asbestos containing sealing materials - (Dixit) (4) Asbestos reinforced molding compound - (Weaver) (5) Asbestos reinforced molded plastics - (Weaver) UCC 010892 AIA STANDARDS AND TECHNICAL COMMITTEE PAGE 3 SEPTEMBER 17, 1974 (6) Asbestos-cement pipe - (ACPPA*, McGinley) (7) Joint treatment compounds - (GDCI** , Rhodes) {8) Asbestos papers - (Fenner, Wilson) (9) Asbestos containing sheet products - (Fenner) (10) Asbestos cement shingles - (Zimmerman) Asbestos Cement Pipe Producers Association Gypsum Dry Wall Contractors International Additionally, W. H. Mortonson is to investigate the necessity for a work practice relating to vinyl asbestos floor tile. This investigation to be done in conjunction with the Reinforced Tile Institute. By copy of these meeting minutes, Fraser Morton is asked to comment on the necessity for a work practice related to flooring roll goods. The timetable for preparation of these documents was discussed. It was agreed by the Committee members that a rough draft of their document could be mailed . to E. M. Fenner by October 18, 1974, E. M. Fenner would circulat^7~"3S--'necessary , for comment. A meeting of the full Committee was then scheduled for Thursday, November 14 at 9:00 A.M. at a motel in the vicinity of O'Hare Airport. By copy of this memo, R. H. Mereness is requested to arrange for a meeting room, preferably at the O'Hare Inn, and a block of eight single rooms for the night of Wednesday, November 13. E. M. Fenner EMF/emr Attach. cc: R. H. Mereness F. J. Solon, Jr. UCC 010893 V. MEETING AGENDA ' STANDARDS AND TECHNICAL COMMITTEE ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA TUESDAY, SEPTEMBER 10, 1974 1. Possible modifications to the AIA/NA submittal to OSHA recommending revisions to their Asbestos Standard. (FENNER) 2. Possible Committee action on: ' a. Amending California Senate Bill 2419 (copy attached) banning the spray of asbestos-containing materials. (FENNER, RHODES) - b. Preparing comments on California State Department of Health paper, "Asbestos in the California Environment", AIHL Report No. 154 (copy attached). (FENNER, RHODES) c. Preparing a reply to letter addressed to Asbestos Information Association from Industrial Marketing Associates, Inc. (copy attached). (MERENESS) - r' 3. Procedure for preparing suggested non-mandatory work practice recommendations for customers of AIA member companies. (FENNER) . * 1 UCC 010894 m ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660 L Slreet. N W Washington. D C 20036 (202)223^1865 23 April 1976 3e % Memorandum For: Dr. Rhodes, Chairman^ Standards and Technical Committee / Subject: Proposed Recommended Workplace Practice Booklet, Asbestos-Cement Pipe Enclosed correspondence from the A/C Pipe Produceres Association in connection with our recommendation to develop a recommended work practice booklet for the asbestos-cement pipe sector of the asbestos industry is forwarded as a matter of interest. Executive Director RHM:em cc: Executive Committee Standards and Technical Committee UCC 010895 April 22, 1976 Mr. Robert H. Mereness Executive Director Asbestos Information Association Suite 91A 156Q L Street, N.W. './ashington, DC 2UQ35 Dear Bob: At AACPP's last Executive Committee meeting, AIA's February 18, 1976, offer to develop a recommended work prac tice booklet for asbestos-cement pipe was reviewed in depth. It was the Committee's unanimous decision that this responsi bility would best continue to reside with the individual mem ber companies of the A/C Pipe Producers Association. Conse quently, while your suggestion was both timely and appreciated, I must formally decline your offer to help and ask that AIA's Standards and Technical Committee not undertake any action relative to asbestos-cement pips. Members of our Executive Committee will discuss this decision with their respective corporate counterparts within AIA. Cordially, cc: A. Kahn Exec. Com.: R. Blankenship G. Barge R. Smith H. Taylor L. Taylor UCC 010896 ASBESTOS INFORMATION ASSOCIATION 1660 L Street, N.W. / Washington. DC 20036 / (202) 223-4885 24 January 1975 Memorandum For: MEMBERS Subject: Recommended Work Practices for Asbestos Industry Members are aware that the Association's Standards & Technical Committee has been working on a series of . recommended Work Practices for the asbestos industry (AIA/NA Memo of 11/11/74 refers). The Committee has completed its work on the develop ment of six (6) Work Practices which, in accordance with the advice of the Association's Executive Committee, are forwarded herewith for comment. After lengthy discussion, it was decided that the six (6) areas addressed cover essential needs for the industry at this time. The Committee is prepared to develop Work Practices in additional areas, as may be appropriate, and suggestions are welcome. Following consideration by the Standards & Technical Committee of any comments which may be received on the enclosures and an informal review with the OSHA Asbestos Standard Project Officer, it is planned to reproduce the Work Practices in pamphlet form for forwarding to members for appropriate distribution to customers of asbestos materials or products. It has been suggested, in view of ultimate distribution of the Work Practices, that the proposed material be reviewed by appropriate personnel in marketing and sales. LA UCC 010897 Page 2 Memorandum For MEMBERS Recommended Work Practices for Asbestos Industry Comments on the enclosures are requested not later than February 14, 1975. For establishing an initial printing order, members are requested to advise the quantity of each recommended Work Practice desired. Please use the enclosed form for this purpose. The Association will maintain a nominal supply of the pamphlets in addition to those initially provided to members. In due course, members will be billed for the cost of pamphlets (yet to be determined) plus shipping charges. Enclosures: 6 Recommended Work Practices: 1. Manufacture and Fabrication of Products Using Asbestos-Filled Resinous Molding Compounds 2. Fabrication and Use of Asbestos Friction Materials 3. Fabrication and Use of Asbestos Reinforced Plastic Products 4. Fabrication and Use of Asbestos Paper Products 5. Use and Handling of Asbestos Textile Products 6. Shop and Field Fabrication of Asbestos Sheet Products Request Form for Recommended Work Practices cc: John H. Marsh, Director, Standards & Technical Activity Area Edmund M. Fenner, Chairman, Standards & Technical Committee Standards & Technical Committee UCC 010898 Date To: Subject: Executive Director, AIA/NA Request for Recommended Work Practices for Asbestos Industry 1. It is requested that Recommended Work Practices in the quantity indicated below be forwarded to _____________________ Company/ Organization And Address QUANTITY RECOMMENDED WORK PRACTICE _________ Manufacture and Fabrication of Products Using Asbestos-Filled Resinous Molding Compounds _________ Fabrication and Use of Asbestos Friction Materials _________ Fabrication and Use of Asbestos Reinforced Plastic Products _________ Fabrication and Use of Asbestos Paper Products _________ Use and Handling of Asbestos Textile Products _________ Shop land Field Fabrication of Asbestos Sheet Products 2. Our comments are appended . We have no objection to the proposed Work Practices as submitted ______. Signature UCC 010899