Document Nb6vpX1YzZkXy9gyK938oyEE

CAPCO PIPE COMPANY, INC. Birmingham, Alabama January 29, 1981 PLAINTIFF'S EXHIBIT TO: FROM: Mr. E. A. Farrell Mr. W. T. Whitley SUBJECT: Cement-Asbestos Pipe Correspondence Attached are some letters from our files that speak specifically to the use of A/C water pipe. These are very much in our favor and really represent the first times, to our knowledge, government agencies and water boards have made favorable comments regarding the use of A/C pipe. I am sure these will be of interest to you. WTW/gj Attachments CAPCO JEN 0006814 FROM: CITY WATER DOARD 10/10/80 (Jack Mullen, Brooks U Associates, 227-3454) Asbestos cement pipe used by the City Water Board in' its water distribution system represents the least health risk to customers, according to a letter received by the utility from the Environmental Protection Agency's regional office in Dallas. Replying to a request from Robert P. Van Dyke, CWB general manager, seeking EPA's opinion on acceptable water pipeline materials, Mac A. Weaver, the region's acting chief of water supply said: "Extensive evidence indicates that in systems having an Aggressive Index (AI) greater than 12. 0, asbestos cement pipe does not dissolve and thereby release asbestos fibers. Such material does represent the lowest health risk pipe material for non-aggressive waters according to the best information available - to us at this time. " Van Dyke explained that using this Index San Antonio's water is classified as mildly aggressive to non-aggressive and is suitable for pipelines made of asbestos cement. He said CWB will continue its investigation of materials being used in the utility's water distribution system to insure they meet all existing regulations and present the least health risk to water users. - 30 - CAPCO JEN 0006815 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VI 1201 CUM STREET DALLAS, TEXAS 75270 October 6, 1980 Mr. Robert P. Van Dyke General Manager City Water Board * 1001 E. Market St. P. 0. Box 2449 San Antonio, TX 78298 Dear Mr. Van Dyke: Thank you for your letter of September 16, 1980 requesting information on the health risks associated with various pipe materials. The Environmental Protection Agency shares your concern. Studies are underway in the following areas: * Animal studies of health effects of ingested asbestos; * Corrosive effects of various water qualities upon asbestos cement pipe and other pipe materials; * Leaching effects of water on organic chemicals associated with various pipe materials. There is also a question of the chemicals used in pipe processing. Organic chemicals can be part of the pipe composition, or a residue . of a sealing or coating material. In addition to vinyl chloride, polynuclear aromatics, epichlorohydrin and polychlorinated biphenyls mentioned in the Region IV response paper, tetrachloroethylene, a carcinogen, has also been detected as a contaminant in vinyl lined asbestos pipe. We agree with the opinions expressed in Region IV's response paper, but caution that it is difficult, if not impossible, for EPA to be aware of the consequences of all processes used by the many manu facturers of pipe materials. Additionally, these manufacturing processes change, and a pipe material which was unsuitable several years ago may be the best choice today due to changes in technology. The reverse could also be the case. It is hoped that pipe manu facturers are becoming more aware of the health effect ramifica tions of their materials and processes. CAPCO JEN 0006816 r 2EPA has not established a list of approved pipe materials, but a major section of the August 27, 1900 Amendments to the National Interim Primary Drinking Water Regulations deals V/ith corrosion control. We are enclosing a copy of those amendments for your information. Although you state that your source water is nonaggressive, I suggest you review the corrosion control section of the Amendments. There are several indices for determining the corrosive potential of waters. Extensive studies have shown that these indices are not conclusive indicators of corrosivity of all waters, due to complexity of the corrosion phenomenon and the differing corrosion mechanisms. Determination of the corrosivity is extremely important in selecting the best pipe material. f* Extensive evidence indicates that in systems having an Aggressive Index (AI) greater than 12.0, asbestos cement pipe does not dis solve and thereby release asbestos fibers. Such material does represent the lowest health risk pipe material for non-aggressive waters- according to the best information available to us at this time. lf I hope this information is helpful to you. Should you require clarification or more information, please contact Mr. Warren Norris, P.E., (214) 767-1762. Sincerely, Mac A. Weaver Acting Chief, Water Supply Branch (6AWS) Enclosure CAPCO JEN 0006817 * 16 September 1980 c 0 Mrs. Adlene Harrison Roglonal Administrator Environmental Protection Agency, Region VT First International Building 1201 Elm Street Dallas, Texas 75210 .. Dear Mrs. Harrison: The attached response paper from Region IV, United States Environmental Protection Agency regarding water pipeline materials Is most Informative. Water utilities are most perplexed In trying to select a pipe material that does present the lowest health risk. I would appreciate your review of this response paper and your confirmation that the opinions expressed do represent the present thinking of the Environmental Protection Agency. The City Water Board Is presently reviewing our present practlcoo to Insure that the material being used for our water distribution system meets all the existing regulations and presents the least health risk to our customers. As you know, tho City Water Board's source of supply Is the Edwards Aquifer which is classified as a nonaggrccslve water and according to tho responso paper asbestos cement pipe should be the best selection. However, your commonts regarding the opinions expressed in this response paper are requested to insure that an erronoous conclusion is not reached. Very truly yours, Enclosure OAB:ld Ccnoral Manager CAPCO JEN 0006818 I >i> couim./fiti i.n.ri.T ATLANTA. I'.l'On ilA . o August 20, 1900 t t jPt 4W-KS * Itr. *P.R. Williams, :5up-:r intendent Vinter Division l`-par tment of Klcolric and Water Util ities P.O. Box 3f>8 1000 Bant Parker dl.n.et lakeland, Florida 33302 ; Boar" Mr, Williams: vh.mk you Cor y.mr I tier of August G, r-<iue.:l ir.g in fori:.* Hon mit . arious pipeline i.- !.; i ls which *re idcrat i-.u Cur -the .aid distribution iding. Ke h.ive :t t.-.v.;;t< d to .mi *..<:r _ y .ir questions in detail, exprocr.iuj vh.tt, in out* upini><n, is the direction .f ii>o i'nviron.-ntnl 'i tection Agency's thinking on those various tutorials ''or u;;e in .shle ,\lvr application. Vhe answers to your questions ..*ic osed as an . t ..hir.ent to this letter. if J can he of fmther are*, is lance in Shis n* it ter please eon! ct me. Wincorely yours. ..'iiclosure Response Paper CAPCO JEN 0006819 RESPONSE TO LAKELAND FLORIDA QUESTIONS CONCERNING POTAHLE WATER PIPE MATERIAL August 20, 1980 1 *f The agency has done no research into cement lined ductile pipe. The seal coat, applied in order to promote proper cure of the cement, is usually a petroleum based material obtained from the "bottom" of the distillation process. We have on record, in Region IV, one instance in which this coating material was found to be contaminated with low levels of polychlorinated biphenyl (PCB). The agency does not have the resources necessary to determine if contamination such as this occurs frequently. It is not expected to be the normal situation, but it is an example of a problem which might occur with this type of pipe. Iron pipe lined with various types of coating material, other than cement, is also widely used in the water supply industry. Coating materials used are, coal tar derivatives, vinyl, epoxy and other types of resin based coatings. The agency, in an ongoing study, has monitored water coming from a large water storage tank to which a coal tar coating was applied. More than twenty organic compounds which could be directly attributed to the coating material have been detected in the water. A number of these were polynuclear aromatic compounds (PAC). The health community has expressed concern about human consumption of PAC in general because several are known or suspected human or animal carcinogens. In the current study, even after more than two years of continuous use PACs are still detected in the water at approximately one tenth (0. 1) the original concentration. In a situation with a vinyl coated pipe material the solvent that was used to clean the pipe and thin the coating for application was found to be present in the water at the parts per million level. Studies looking for vinyl chloride in water from vinyl coated pipe have not been conducted at this time. Thus, the possibility for vinyl chloride contamination of water passing through such pipe is only conjectured. The agency has expressed concern for the fact that many epoxy coatings use epichlorohydrin in their formulation since this compound has been determined to be a carcinogen. A study to determine if this material is present in water contacting epoxy coatings will need to be conducted in order to determine the significance of the agency's concern. CAPCO JEN 0006820  2~ Many coating products have components for which the agency health effects personnel have concern when considering long-term human consumption even at very low concentrations because of their identification as known or suspected human or animal carcinogens. As indeed these same'individuals have a similar concern for the long-term ingestion of asbestos fibers. 2. An agency study of installed polyvinyl chloride (PVC) pipe found low levels of vinyl chloride in the water after transmission through the main. Vinyl chloride has been linked with increased incidence of liver angiocarcoma among the vinyl chloride industry employees. Both long-term and high level exposure to vinyl chloride has produced the same type tumors in laboratory animals. The National Academy of Science (NAS) assessment is that, vinyl chloride is a human and animal carcinogen. The NAS assessment of carcinogenic risk to the human population indicates that there would be a risk of one additional cancer per million persons consuming water containing 2.0 micro-grams per liter for a lifetime. Other plastic materials have not received widespread use in the water supply industry for pipe diameters to which you refer; therefore, discussion of the appropriateness of their use in your system will not be addressed. 3. The agressiveness of the water has no known affect on the teachability of chemical compounds from PVC pipe or the various coating materials previously discussed. The leaching process will occur, on a continuous basis, from the pipe or coating into the water based completely upon the laws of physical chemistry. The driving force for the transfer from the pipe or coating (organic phase) into the water is the difference in concentration for a given component in each phase. This force is independent of the aggressiveness of the water. On the other hand asbestos-cement pipe suffers dissolution .of the cement ir. a chemical reaction in which the cement is dissolved releasing the asbestos fibers which is very dependent upon the chemical quality of the water, specificly its aggressiveness. 4. Since, as indicated previously, there are some health risks associated with use of most of the pipe materials in question, it would appear that selection should be toward the one in which the suspected health risk can be reduced or eliminated. Since the problem with the coatings is a leaching of contamination from the film into the water and independent of water quality, and the problem with the asbestos-cement pipe independent upon the water quality which can be (and in the proposed application will be) controlled through treatment, then it would appear that the pipe system with the least negative health effect prospects would be the asbestos cement pipe. CAPCO JEN 0006821 * 3 * The chemical reaction between water and cement has been successfully Etopped by two methods. One is the application of treatment which alters the aggressiveness of the water so as to make it nonaggressive (as defined by the equation for the Aggressive Index). The other is the addition to the water of a zinc salt which allows the formation of a zinc hydroxide percipitatc on the pipe wall thereby establishing a protective barrier between the water and pipe. Where treatment to adjust the water quality so that it is no longer aggressive is available, this is the best approach in controlling asbestos cement pipe degradation. The health risk associated with use of any of the pipe systems discussed would indeed be very small. The general order of increasing health risk for nonaggressive water would be asbestos cement less than cement lined less than polyvinyl chloride, vinyl coated, epoxy coated, other resin base coated, with coal tar coated the greatest. The fact that Lakeland has several hundred miles of asbestos cement pipe already in use should not influence the decision to use asbestos-cement pipe in the proposed project. What must be considered is how will the use of such pipe in this project impact the public health. From the proposal it is clear that the utility intends to use this pipeline to convey only stable nonaggressive water to its customers. Thus, the pipe would not degrade and asbestos fibers would not be present in the water and the public health would not be endangered. The facts have been established by EPA studies that asbestos-cement pipe has been used across the United States for many years conveying nonaggressive water without the slightest indication of deterioration or asbestos fibers in the water. However, aggressive waters have been found in many places to cause pipe deterioration resulting in asbestos fibers in the water. Lakeland's drinking water is of such quality that there is indication that asbestos-cement pipe deterioration has apparently already occurred in the 300 miles presently installed. The utility's plans for construction of a complete treatment facility, which will provide stabilised water that will put an end to further pipe deterioration, should be quickly accomplished in order to eliminate whatever asbestos fiber health hazard that may presently exist. CAPCO JEN 0006822 A/C Pipe Producers Association Tf Jt'ttjo Internal Correspondence ToPublic Affairs Committee International Affairs Committee c_. --...- J. F. Welch, Director, Public Affairs DATE: November 12, 1980 S00JECT:Field Problem - San Antonio, Texas REF: Regulatory Affairs, Field Problems and Asbestos Research Report, October, 1980 ACTION REQUIRED: jReview for information and dissemination Enclosed is correspondence from the Acting Chief, Water Supply Branch, Environmental Protection Agency, Region 6 to Robert Van Dyke, General Manager, San Antonio Water Board describing the Region's position on the potential health risks of A/C pipe. This opinion .is not dissimilar from that of EPA Region 4 (previously routed) in that it is stated that the use of A/C pipe in non-aggressive waters, i.e., Aggressive Index greater than 12.0, represents the lowest health risk of all pipe materials. Also enclosed is a press release made by the City Water Board on receipt of the EPA letter. Staff recommends that the Region 6 letter be disseminated to ' field sales personnel for use in counteracting field problems. JFW/ajb . Enclosures cc: A. Kahn, Esq. N. Rahn, Esq. B. Pigg (AIA/NA) N. Battle (L&G) copies to: Public Affairs Committee International Affairs Coinnittee H. Olson I. Adams B. Cook l)iKPerrell J. Woods 0. Baker T. Dougherty D. Stinson VI. McCallie R. Dorner E. Van Der Rest B. Giboin C. Walters R. Hobbs A. Saoulis R. Oalan V. Pattabhi H. Hudson C. Barton S. A1 -Tarkait FP/1 Chrono CAPCO JEN 0006823 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY iiccion vi 1201 CLM STHEET DALLAS, TEXAS 75270 ' October 6, 1980 ........ Hr. Robert P. Van Dyke General Manager City Water Doard , * 1001 E.. Market St. P. O. Box 2449 San Antonio,. TX 78298 . ....... . Dear Mr. Van Dyke: Thank you for your letter of September 16, 1930 requesting information on the health risks associated with various pipe ' materials... .. . ...... .................................. The Environmental Protection Agency shares your'concern. Studies ..are underway .in the following areas: . -y ..Animal studies of health effects- of ingested asbestos; . : ; ... , Corrosive effects of various water qualities upon asbestos cement pipe and other pipe materials; .* Leaching effects of water on organic chemicals associated with various pipe materials. There is also a question of the chemicals used in pipe processing. Organic chemicals can be part of the pipe composition, or a residue of a sealing or coating material. In addition to vinyl chloride, polynuclear aromatics, epichlorohydrin and polychlorinated biphenyl mentioned in the Region'IV response paper, tetrachloroethylene, a carcinogen, has also been detected as a contaminant in vinyl lined asbestos pipe. We agree with the opinions expressed in Region IV's response paper, but caution that it is difficult, if not impossible, for EPA to be aware of the consequences of all processes used by the many manu facturers of pipe materials. Additionally, these manufacturing processes change, and a pipe material which was unsuitable several years ago may be the best choice today due to changes in technology The reverse could also be the case. It is hoped that pipe manu facturers are becoming more aware of the health effect ramifica tions of their materials and processes. CAPCO JEN 0006824 -2- EPA has not established a list of approved pipe materials, but a major section of the August 27, 1980 Amendments to the National Interim Primary Drinking Water Regulations deals with corrosion control. We ere enclosing a copy of those amendments for your information. . Although you state that your source water is nonaggressive, I suggest you review the corrosion control section of the Amendments.- There are several indices for determining the corrosive potential of waters. Extensive studies have shown that these indices are not conclusive.indicators of corrosivity of all waters, due to complexity of the corrosion phenomenon and the differing corrosion mechanisms. Determination*of the corrosivity is extremely important in selecting the best pipe material. `Extensive evidence indicates that in systems having an Aggressive Index (AI) greater than 12.0, asbestos cement pipe does not dis solve and thereby release asbestos fibers. Such material does r represent the lowest health risk pipe material for non-aggressive waters according to the best information available to us at this time. I hope this 'information is helpful to you. ` Should you require clarification or more information, please contact Mr. Warren Norris, P,.E., (214) 767-1762. ' Sincerely, Mac A. Weaver . ' Acting Chief, Water Supply Branch Enclosure . '* (6AWS) Ws . CAPCO JEN 0006825 V r. .V t . ' ' ' . ' 16 September 1980 # Mrs. Adlene Harrison Regional Administrator Environmental Protection Agency, Region VI . First International Building 1201 Elm Street Dallas, Texas 75210 Dear Mrs, Harrison: - The attached response paper from Region IV, United States Environmental Protection Agency regarding water pipeline materials Is most Informative. Water utilities are most perplexed in trying to select a pipe material that does present the lowest health risk. I would appreciate your review of this response paper and your confirmation that the opinions expressed do represent the present thinking of the Environmental Protoctlon Agency. The City Water Board Is presently reviewing our present practices to Insure that the material-being used for our water distribution system meets all the existing regulations and presents the least health risk to our customers. As you know, tho City Water Board's Bource of supply is the Edwards Aquifer which is classified as a nonaggresolve water and according to the *#f response paper asbestos cement pipe should be the best selection. However, n your comments regarding the opinions expressed In this response paper ` i. are requested to insure that an erroneous conclusion is not reached. Very truly yours. Enclosure OABsld Robort P. Van Dyke General Manager CAPCO JEN 0006826 Ui'Y WATER BOARD 10/10/80 (Jack Mullen, Brooks & Associates, 227-3454) i Asbestos cement pipe used by the City Water Board in its water distribution system represents the least health risk to .customers, according to a letter received by the utility from the , . . Environmental Protection Agency's regional office in Dallas. Replying to a request from Robert P. Van Dyke, CWB general manager, seeking EPA's opinion on acceptable water % pipeline materials, Mac A. Weaver, the region's acting chief of water supply said: ''Extensive evidence, indicates that in systems having an Aggressive Index (AI) greater than 12. 0, asbestos cement pipe does not dissolve and thereby release asbestos fibers. Such' material does represent the lowest health risk pipe material for non-aggressive waters according to the best information available to us at_this time. " Van Dyke explained that using this Index San Antonio's water is classified as mildly aggressive to non-aggressive and is suitable for pipelines made of asbestos cement. He said CWB will continue its investigation of materials .. being used in the utility's water distribution system to insure they meet all existing regulations and present the least health risk to water users. - 30 - CAPCO JEN 0006827 CAPCO PIPJ- COMPANY, INC.--a SuhiJUry of ASAttCO Incorporated 1400 Twentieth Street, South * 7*. O. Box 3430 / Birmingham, Alabama 35233 * Hone 205 * 033-7201 CARL D. WOODWORTH Ctnaraf Safes Manager October 14, 1980 Mr. William Gillespie City of Gastonia Post Office Box 1748 Gastonia, North Carolina 28052 Dear Bill: Per your request, I have attached a copy of "A/C Pipe and Health" which should answer any questions you have. I have also attached a copy of a recent letter from the EP.A Division IV which put out an opinion on pipeline materials for Lakeland, Florida when a concern was raised over asbestos and water. *. .. * If you have any further questions, please do not hesitate to call Yours **------- C. B. Woodworth CBW:mf Attachments bcc: Mr. A. B. Stapp II Quality Piping Materials CAPCO JEN 0006828 i* /.n ;; 1? UNITED STATES ENVIRONMENTAL PROTECTION ACENCY region iv US couurt.Atio smart Atlanta. ccohoia ;woo August 70, 1900 . # REF: 4H-KS ... I . Mr. T.B. Williams, Superintendent Water Division Department oil Electric and Water Utilities P.O. Box 368 1000 East Parker Street . ' Lakeland, Florida 33302 Dear Mr. Williams: ... . ` .. * . * Thank, you Cor your letter of August 6, 1980, requesting information about various pipeline materials v;hich are under consideration for the Lakeland distribution system upgrading. We have attempted to answer your questions in detail, expressing what, in our opinion, is the direction of the Environmental Protection Agency's thinking on these various materials for use in potable water application. The answers to your questions are enclosed as an attachment to this letter. . If I can be of further assistance in this matter please contact me. * Sincerely yours, Response Paper CAPCO JEN 0006829 RESPONSE TO LAKELAND FLORIDA QUESTIONS CONCERNING ROTADLE WATER PIPE MATERIAL August 20, 1900 t* The agency has done no research Into cement lined ductile pipe. .The seal coat, applied in order to promote proper cure of the cement, is usually a petroleum based material obtained from the "bottom" of the distillation process. We have on record, in Region IV, one instance in which this coating material was found to be contaminated with low levels of polychlorinated biphenyl (PCB). The agency does not have the resources necessary to determine if contamination such as this occurs frequently. Xt is not expected to be the normal situation, but it is an example of a problem which might occur with this type of pipe. Xron pipe lined with various types of coating material, other than cement, is also widely used in the water supply industry. Coating materials used are, coal tar derivatives, vinyl, epoxy and other types of xcsin based coatings. The agency, in an ongoing study, has monitored water coming from a large water storage tank to which a coal tar coating was applied. More than twenty organic compounds which could .be directly attributed to the coating material have been detected in the water. A. number of these were polynuclear aromatic compounds (?AC). The health community has expressed concern about human consumption of PAC in -general because several are known or suspected human or animal carcinogens. In the current study, cv.en .after more than two years of continuous use PACs are still detected in the water at approximately one tenth (0.1) the original concentration. Xn a situation" with a vinyl coated pipe material the solvent that was used to clean the pipe and thin the coating, for application was found Lo be present in the water at the parts per million level. Studies looking for vinyl chloride in water from vinyl coated pipe have not been conducted at this time. Thus, the possibility for vinyl chloride contamination of water passing through such pipe is only conjectured. The agency has expressed concern for the fact that many epoxy coatings use epichlorohyr.rin in their formulation since this compound has been determined to be a carcinogen. A study to determine if this material is present in water contacting epoxy coatings will need to be conducted in. order to determine the significance of the agency's concern. Many coating products have components for which the agency health effects personnel have concern when considering long-term human consumption even at. very low concentrations because of their identification os known or suspected human or animal carcinogens. As indeed these same individuals liavc a similar concern for the long-term ingestion of asbestos fibers. c CAPCO JEN 0006830 -2- An agency `study of Installed polyvinyl chloride (PVC) pipe found low levels of vinyl chloride in the water after trnnsaission through the main. Vinyl chloride has been linked with increased incidence of liver opgiocarcoma among the vinyl chloride industry employees. Doth long-term and high level exposure to vinyl chloride has produced the same type tumors in laboratory animals. The National Academy of Science (NAS) assessment is that/ vinyl chloride is a human and animal carcinogen. The NAS assessment of carcinogenic risk to the human population indicates that there would be a risk of one additional cancer per million persons consuming water containing 2.1 micro-grams per liter for a life time. Other plastic materials have not received wide spread use in the water supply industry for pipe diameters to which you refer; therefore, discussion of the appropriateness of their use in your system will not be addressed. ' The agressiveness of the water has no known affect on':thc leachability of chemical components from PVC pipe or the various coating materials previously discussed. The leaching process will occur, on a continuous basis, from the pipe or coating into the water based completely upon the laws of physical chemistry. The driving force for the transfer from the pipe or coating (organic phase) into the water is* the difference in concentration for a given component in each phase. This force is independent of the agressiveness of the water. On the other hand asbestos-cement pipe suffers dissolution of the cement in a chemical reaction in which the cement is dissolved releasing the asbestos fibers which is very dependent upon the chemical qualtiy of the water, specificly its agressiveness. .Since, as indicated previously, there is some health ricks associated with use of most of the pipe materials in question, it would appear that selection should be toward the one in v?hich the suspected health risk can be reduced or eliminated. Since the problem wi th the coatings is a leaching of contamination from the film into the water and independent of water quality, and the problem with the asbestos-cement pipe _is dependent upon the water quality which can be (and in the proposed application will be) controlled through treatment, then it would appear that the pipe system with the least negative health effect prospects would be the asbestos cement pipe. She chemical reaction between water and cement has been successfully Stopped by two methods.. One is the application of treatment which alters the agressiveness of the water so ns to make it nonagressivc (as defined by the equation for the Agreesive Index). The other is the addition to the valor of a nine salt which allows the formation oC a nine hydroxide pcrcjpitnte on the pipe wall thereby csfcnblishng a protective barrier between the water and pipe. CAPCO JEN 0006831 3 Where treatment to adjust the water quality so that it is no longer digressive is available# this is the best approach in controlling asbestos cement pipe degradation. * , The health risk associated with use of any of the pipe systems discussed would.indeed be very small. The general order of increasing health risk for nonagressive water would be asbestos cement loss than cement lined less than polyvinyl chloride, vinyl coated, epoxy coated, other resin base coated, with coal tar coated the greatest. * The fact that Lakeland has several hundred miles of asbestos cement pipe already in use should not influence the decision to use asbestos-cement pipe in the proposed project. What must be considered is how will the use of such pipe in this project impact the public health. From the proposal it is clear that the utility intends to use this pipeline to convey only stable nonagresseive water to its customers. Thus, the pipe would not degrade and asbestos fibers would not be present in the water and the public health would not be endangered. The facts have been established by SPA studies that asbestos-cement pipe has been used across the United States for many years conveying nonagressive water without the slightest indication of deterioration or psbestos fibers in the water. However, agressive waters have been found in many places to cause pipe deterioration resulting in asbestos fibers in the water. Lakeland's drinking water is of such quality that there is indication that asbestos-cement pipe deterioration has apparently already occurred in the 300 miles presently installed. The utility's plans for construction of a complete treatment facility, which will provide stabilised water that will put an end to further pipe deterioration, should bo quickly accomplished in order . to eliminate whatever asbestos fiber health hazard that may presently exist.. . CAPCO JEN 0006832 A/C Pipe Producers Association to.Public Affairs Committee International Affairs Committee /: I'Ye.hfi-, ----. 0. F. Welch, Director, Public Affairs Cfff /1-//-STO Internal Correspondence date: December 2, 1980 SUBJECT'Erivironmental Protection Agency - Region 6 Letter on A/C Pipe REF: JFW correspondence, "Field Problem - San Antonio, Texas," November 12, 1980 ACTION REQUIRED: Review for information and dissemination Enclosed is additional correspondence from the Water Supply Branch of Environmental Protection Agency Region 6 explaining its position on A/C pipe. This letter, provided to Staff by the San Antonio Water Board, appears to be written to a concerned citizen. This second letter is, in Staff's judgment, even more positive in tone than the letter to the San Antonio Water Board. Not only does the author reaffirm the nonsubstitutability of asbestos in A/C pipe, but also states: No conclusive scientific evidence has yet linked gastrointestinal cancer incidence with ingestion of asbestos through drinking water. Staff recommends that the Region 6 letter be disseminated to field sales personnel for use in counter-acting field problems. OFW/ajb Enclosures cc: A. Kahn, Esq. N. Rahn, Esq. N. Battle (L&G) copies to: Public Affairs Committee International Affairs Committee H. Olson I. Adams 8,/Cook L-tf. Perrell 0. Woods 0. Baker T. Dougherty D. Stinson W. McCallie R. Dorner E. Van Der Rest B. Giboin C. Walters R. Hobbs A. Saoulis R. Jalan V. Pattabhi H. Hudson C. Barton S. Al-Tarkait UEGA/1 Chrono' CAPCO JEN 0006833 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY necioN vi 120*1 ti.M VIMLr.T ' Dallas, il xas /.i*,/o .* October 30.r 1900 Hi* rf lyn Rife 101 Arcadia Place.. 310 San Antonio, TX 78209 Dear Ms. Rife: Thank you for your letter of October 2, 1980. We share your concern with u reports of asbestos in drinking water. The Environnental Protection Agency (EPA),, Region 6` office, has been in commu nication with the Texas Deparbiient of Health, the Edwards Underground Water District, and the City Water Board of San Antonio since reports of asbestos ` in.-San Antonio's water began. We have also consulted with our own EPA re-'. **' search and health effects laboratories and our technical support division. Based upon our findings, we do not believe the citizens of San Antonio are subject to.any measurable health risk from asbestos in their drinking water. There are two possible sources of asbestos'in' San Antonio's water.' These are from naturally occurring sources in the ground water,, and-asbestos fibers . from the asbestos-cement water pipe. . * In our communications, the Edwards Underground Water District has-confirmed that portion's of the Edwards Aquifer have asbestos-bearing rock formations which yield small amounts of asbestos to the ground water. Present scientif ic information does not indicate that these levels represent a significant. .. health risk. However, water "samples of the source ground water in the San Antonio municipal water supply do not indicate the presence of asbestos. * The second possible source is asbestos-cement pipe. Asbestos-cement pipe . ha.s been widely used throughout the United States for over 40 years. Its advantages are high strength, relative low cost compared to other materials, and resistance to soil corrosion. This high strength results from asbestos fibers mixed in the cement which act as reinforcing agents in the hardened ..concrete. Despite extensive research, no satisfactory substitute for the . asbestos in the compound has been discovered. When asbestos-erment pipe is used to transmit highly corrosive waters, '.deterioration of the concrete can occur, releasing some of the asbestos fibers. Asbestos-cement pipe has been the subject of extensive studies, and ** these indicate that noncorrosive source waters such as found in San Antonio, do not attack asbestos-cement pipe, and no fibers are released. CAPCO JEN 0006834  recently conducted tests to determine if a commonly used method and tapping for new connections released asbestos particles into tnhee~wwaatf>ter-rIj" MSammopllees taken during this testing confirmed the release of ' -the metliod of drilling and tapping has been changed so that these . particles are prevented from getting into the water. Subsequent tests show np-cde tec table levels of asbestos in the water. lyrjrrr-x? ,* Because of the acknowledged health problems related to .asbestos inhaled /anil/or ingested by workers in occupational exposure, it is natural for * people to extend this concern to other exposures. EPA and the scientific community have felt, that extensive-study is justified to determine if there is a level at which asbestos in drinking water might represent a measurable risk to public health. .Ho conclusive scientific evidence has yet linked gastrointestinal cancer incidence with ingestion of asbestos throuqh drink ing water... . .= : . I appreciate your concern for public, health protection. Please be assured that we will continue to stay in touch with the agencies involved in main.taini'ng the quality of water in the San Antonio area, and we will advise them of the continuing research findings both in our own agency and the scientific community at large. ....... . Sincerely.., Mac A.-Weaver, Acting Chief Water Supply Branch. (6AWS) cc: .C. K. Foster, P.E. G. H. Scherwitz, Jr., P.E. ' Thomas P. Fox Robert P. Van Dyke 1/ ^ U.S. Environmental Protection Agency Washington, D.C. 201G0 . Water Supply Staff ** CAPCO JEN 0006835 .A. M@ .A/C Pipe Producers Association Public Affairs Committee to International Affairs Committee ^ f-. -------- - Ffit/T/J- F. Welch, Director, Pualic Affairs Internal Correspondence DATE: February 4, 1981 SUBJECT, Philadelphia, Pennsylvania - Television Program on A/C Pipe ACTION REQUIRED: Review for information IfE&O v\ CArCS On January 7, 1981, Lewis a Gilman reported that Certain-teed /l* Corporation had been approached by WPVI (ABC)-Channel 6 Philadelphia to participate in a series of broadcast on asbestos in drinking water. Certain-teed declined participation on the basis that it would be more appropriate for AACPP to appear on the industry's behalf. Lewis & Gilman recommended that AACPP Staff be interviewed for the program since it would be broadcast in any event and it would be more desirable to put forth the industry's position on the safety of A/C pipe. It is probable that WPVI's interest in this subject resulted from either a series of consumer advocate articles on asbestos in Philadelphia area -schools or tiie Ocean County, New Jersey field problem. An article in the Ocean County Reporter (Attachment 1) claims credit. On January 7, 1981, the President was interviewed for approximately 25 minutes by WPVI reporter Jim O'Brien. The interview was simultaneously video-taped by a firm retained by Lewis & Gilman. Tapes of the broadcast also were obtained by L&G. The three part series, entitled "Trouble in the Tap," aired on the 11:00 p.m. "Action News" program January 12, 13 and 14. The comments conveyed to Staff by industry viewers suggest that the impact of the program was negative. The reporter characterized A/C pipe as a controversial product about which much is unknown. Officials from EPA (Jim Kn'llette), the Fox Chase Cancer Center and private water utilities also were interviewed. As expected, their respective views on safety of A/C pipe fell into the classic pigeon holes. AACPP's comments on air were related to explaining the ban in Connecticut and the release of potentially toxic substances from other pipes. The last part of the series listed sources of information on asbestos ar.d drinking water. L&G was successful in having AACPP's address and telephone number shown along with that of the Fox Chase Cancer Research Center. If viewer response is a valid barometer of public concern then the series may not be as negative as perceived. AACPP received only four telephone calls and one letter. Moreover, a discrete call to Fox Chase Cancer Center revealed that it was advising the public that there is no evidence that asbestos in drinking water is dangerous. CAPCO JEN 0006836 -2- It also is likely that the series resulted in the publication of a news article (Attachment 2) in the Burlington County (New Jersey) Times. If you have any questions, please do not hesitate to call. JFW/ajb cc: A. Kahn, Esq. N. Rahn, Esq. M.~Greenberg, Esq. N. Battle (L&G) copies to: Public Affairs Committee International Affairs Committee H. Olson I. Adams . B. Cook . ` W. Perrell J. -Woods J. Baker T. Dougherty . . D. Stinson W. McCallie R. Dorner E. Van Der Rest' B. Giboin C. Walters R. Hobbs. A. Saoulis R. Jalan V. Pattabhi . H. Hudson C. Barton S. Al-Tarkait'1 E. Costa FP/1 Chrono CAPCO JEN 000683T ** Trouble at the Tap.'* 8 three-part news series broadcast by NV?VI, Chan nel 6 in Philadelphia, his alerted thousands of televi sion viewers in the Dela ware Valley area of the potential health problems posed to humans by asbes tos - cement pipes when they are used to convey corrosive drinking water supplies. Following the lead of in vestigations being con ducted in Ocean County, WPVI proceeded with an independent search for in formation about the eon- ' trovmia) asbestos-cement pipes. Eric f-!oenfe!d. pro ducer of u:e specie serins, said tbs station was not trying to frighten : view ing audience by presenting the unanswered questions about the dangers of in gested asbestos to human beings. Schoenfeld said that right now, he personally, is not worried about drinking den for protecting drinking water supplied through as water supplies will rail on bestos - cement-pipes. He the water companies be-' does c& believe, however, " cause standard home filters that we should adopt the -have no effect on micros philosophy that no one has copic asbestos f.bcrs. proven there :s any positive Environmental Protec danger, therefore nothing tion Agency officials told is-wrong, ns stated in part Channel 6 that water com two of the series by a rep panies. in addition to ad resentative of the Asbestos ding lime to water to make - Cement Pipe Manufac it non - corrosive, can.re- turer Asociation. Ilae the inside of pipes to Id part three of the series prevent asbestos fibers this week, WPVI told vie from entering the water wers that the primary bur-. supply. CAPCO JEN 0006838 V .. ;**A*G* C|A*- * v lUnjNC. TO'N'COOKrYtMJjTIWB*. * "'**** ^ '''*. i' 'No 'proven* risk ^ -iV ^-viv'k ^ > /: \ . > ** ?,/ - . -f/_ _ 1 M* | "Sfc .-S'*'-1- V V' -IV? By MAM a. CintALNICr..'.li--'and lithe - "|5'V' wT w* v'; water It aggressive Abate... ! OfthtBCTStoff ` -' ,, 12, the water taooo-aggrvsalve,adthe c-'a*y'V, Majot'water utlllBea serving-Bur- .rishofcootamtnatioQlsmfnlniaL '. .Ungtoa-County rely partly oa under- . ; By talas this formula, tha Burling-,' ~C*r ground pipe* made with asbestos, a. , tea County .Times baa determined that " known cancer-causing agent.'And a several water utilities setting th court- . '; ri .special scientificfonnula which would- ty fall between id and 12--ttqaggrt*-' . "air determine the risk of drinking that wa- sire looe. I tor-shows, to fact,that mast of too wa- ' Far example, tha Medford Water,* :>.:tjv ter companies fail'wtthln the danger ,Company,whichserves^omaUMcu*;' ' fT'ioo*. ' 1?:~: `f. ': . r toraers north of Tuekerton- Road la . *'*-ii . However.-whlle the risk exists.tbe<8*.,i Medford Townsbip,.has* pH of 7.5, ae-.,': i' .Ilf medical erldeace'-that anybody hiS 'ter equals *0, aad the hardness of the : 'jfi ever contracted ao'asbestos disease/- pipes equals <2. The product of those i ..if* from drinking water; . *' 1-.*.`V: twofactors multiplied togetherit 7,380. '] -*' < *J* ^ pipes, which have recently boA-Tbe logarithm, of 7,380 can be rounded - .w- About tee percent of the Medford-tV-sey-Woter-Coupony, whJchratestl.l*; t. S''Water Company's piping system Is A-C- oo tbe aggressiveness-sealer, and tbe-i J'i.-ir.Plpe*; The Mount Holly Water Compa-l-Mouat-Holly Water Company, which'.1 ; ;; t * ny is 30 percent A-C Pipes, and the New/- 'rates.l2r? I-;, f-t.*-,*-... i] Jersey Water Company U-abtutg per-.k*. Thesestatistics olooe would suggest.'] tv- cent. The Lake Valley Water Cofnpanjr/l-thst many utility customers In Barling- ; ^I^tbertcS'osmshlp.usestilA-C pipes..;, Vispossibly aggresatweenoaghtodeterf---; >, >!. "Scientists-say It la possible for tho->arate the Insides of the- ptpes.thrpuglf.i jjj asbestorto flske'off the Inside'bC.the"-'. whichtrtravels. J.- ve.V--.-f ry'j-2 '-"'Hi EfVK* and travel through the system to However, the pipe manufacturers;.; el - .fit borne water taps If the add content to.;> utility companies and medlcalrer i f. J.i'thewsterbecomes-,toohigh. . ,'* .-'./searchers, argue that there Is. littlev'iX'J i'.-- When tho water bocomes-addlc. Itt/'anyoprovetrrisk.'.*^' ,'i't jlabecomes aggressive, in water company ^ -- For example,the-NedJersey Watert if. trSterms; Aggressive- water.iaa. cansef:Company-to Paimyra uses.a,chemicals a plpo to deteriorate. v. -e '. . sequestering agent known' as-sodium; i-'; :ScIentists have developed a complex- - beaamete phosphate. Tanks ol this a ;' >Jformula to'determine the aggressive-.'-. compound are stored inside the Cooper, ;-I*nei c-f- the water one drinks sod todo- JStreet statiaa to Edgewxter Fa|h --v Siteraine thereby ifhois rnnnbg'therisk .'amoog.otbejr places -- wherwtbey nre.f 'k.. i^Iofasbe-tosdeteriorationlo the plpesi ;. -pumped Into the-water-supply to bold t C*'," Since asbestos abersareminute and-k the-iroo.and manganese, particles tor t* *!-Jofteninvisible.thasverigebomeowoet .'suspension.-',* y .- c-.tjoi--y. .-j ?. Vs! onuldnot determlnetbo potentialpurity, By doing so, tha Ironadd manganesef A--Ujof his-waSer-vrithoubthis-formuto-orr-sron't-oildlr*:sod thewaterwnalttnap- jj '.'(jlsomakindolmfcroscoprcahalyslsi. ^'.vtoanotbercolor. .''tVvV-s'1*--'.ij ( Themate factorto tho formulalathe.'.." The process also1 makes' thchrater*. h ; of thawater.-The pH refers to bow .Jess aggressive,-according to Kenneth-. -. jfacHIc the watorn and is ffiecauredoaa>\ Wntgg. the manager: But be said that ,'t -idJscileafbtdM.ApKof I is highly adA-. since the scientific formuladoesn'tfo<? t v A pH of 14 la "basic." meaning the-. - tar to the effect of the* sodium cem- i water contains a high alkalL-ve content. . pouod, people may think the company's ` . a& pitotTis neutral. Ms ny people pur--rwater is tnoreaggreuiee tboa it rtollyr ^'-3icbas4pB-Tbasedshampooabecauseof'"isi^-.'.'.,-- -- k > *. ; S .'.'^ijthe favorohle effect It baa'oaIheirhair-. C The Moual HcBy Water Company, a/ ycataxturs- .. *''whollyowsed subsidiary of'the Eliza-- i' Inthisrrglon.'thepHdfweUwaterfs- bethtown Water Company, has.been us-, i.' j*,aonually Jtor slightly scldic. So,ta lyv lng A-C Pipes for40years. AboutM per- ' > j|Jcrease the pH, water utaides often feed -cent of'tba company's. system has *^;uic>7*bcnrdu9cvnpaw9ww wc iucq uk>h pipn>nyyinws -JJ - There are two other key factors-In -Arthur Cross, president of tho.comps-; ' y-tbe formula. The first Is the alkalinity;' 'ny. "There's never been any- proven: -. "aJibe second Isa number assigned tothe' bad effects from the use bf.the pipe*; ' -Hhartiness cf the pipe: Toe alksUnltyls - themselves. We keep our pH between -- JfrmulUpUed times the hardness number. 7.lsnd8allthetime.? ' wjlhen the logsrithm of tost product is ' Cross said'that monthly 'chemical {,' J-determind. A logarithm Is the expo- 'analyses of the company's watersupply 1 -.Jnent Indicating the power to which tea have-revealed no asbcatoa.csat*nt lomust he raised to get the number to whatsoever. ' ' ' 1 -* iw-1!L..' i^jq'iloWeQsUUoWa.. - . I-- T1QhCe ULaKkeI VTaUlle7y-WYTaStIeCrr \CMotmapp*a0n7y., v. yj . Odcc that number U drtrrmlned* It ^wblch serm 450 units In 29 apartment { *is added to the pH to determirn lTthe buiMlnp in tha Lake Valiey section of to^irater ts aiticresslve or aoL If thesam ' Pemberton Township, havbceo using. ' -'>JalUb*tv'*fluDdlO,thft*>t;rfscoa * all AC pipe* since the system was built j.' ^3sldered highly aggressive, iktween. II. between l>5t and 4570. John Stroks, the ,| I ' *' * '__ _____________ ___ , CAPCO JEN 0006839 . y .-' . . : / . >: SUNOAY.JAhKJAIY,* r- x \ .. ,, ..--I:.; T ?'; .-. ' II '...'-t -.-OV.V >. *>#\ y ,e *^*44 ? HOW PURE IS YOUR WATER? ' - --U -V --v '? . ^Caustic. sjpda/puinp^d inter-. - - - -. s,. v*. .-'i-* ^Tofcat water wuppliesj;*' * through thi: equipment -, ' .(below) at the.New- Jersey vi ?..Water;.Co'mp*ity, 'Cooper.'` /Street stado^inEdgewatet.. cFaii/raises th pH;6f-,the.- Jyaieir 'aadtj'Secreaseyvthe.V J^lMaAPatiAW APm *** ` ,, (... -, 1 --------------------------- --- . ., iT yyi Ky/.tiSo'uiiiniiKny*^ *of oM*rtAb*ra tju>fcQeaK<n*pfei hwighlny olpfytfWcwiibia* ^r*w'*.-,4* *- --i Iftoad llfrjp w gymm.wd ibw< \7 itoy o> mb nymm /company president; saldbedldn'fknQiK; -charge thata deteriorated pip* ptwes a- .were totroducedlntomiayof the water ) i-thenggresaivetodexofhiswateroranyr, 'potential public healthprohlent -Vv>./systems* /. -i fof the(actontt the formula. Hswsves^ ,-.!:McCaUie-claIms-tbere-hti-.HeTer-h...:To data&ooly ooe-ltudy baa.come J tibestfd, "Wedotftbeveany.agzixsstve-.'Ibeea a.demonstrated-health risk trom'i.dnse to placing hlameoaA-C pipe* for i watem**-'>-.- - X-tS/?*??+&-asbestos-to pipes? bopointsocetbstIf- gastrointestinal cancerrates.;The ihi- i Sr- The New-Jersey Department*b.. tbewitertosggresslve. "ttwilleetiop;;,dy was pertormed latheSan Francisco,!, sHesJthhas conducted n-xttudies to de4i -peEpIptsJrori,- copperfittingscoilron>*Bay areaby Dr. Robert Cooper and his' 1 t termtoe. tbo'aggras.deeneia'of -vatar\ .fltttogj."; yVT`"S**a-f.W i*~-1 stodeattMarty Kanarak, of-tbe Unrrer^' j .rasdU.tofact;a(greas!re<nt<irhaai>;i. ';CertataTeed.Corporatloo lo'Vallej l.-.rity ot-Califonla. The results pototed 4 -promolgated1 aajr tejolatfoM-Oa per*/adds.^Thereto txj>vldence that"aoy*?.SS^SClSihJSdStoai-turrit?to! 1 miilblea**ioaivity terete ooe to the geeeral public has_ ever coo- r `,^0^ hare dectored It totally to- . "accurate, there Is no medkalproof tost hire alsofailed topnrreany.rislu:.'-;-J. Builder &'-n(toeer claims the entire,- i 'anybody has taken 111 aarresult of S- -^- In 1S79, the American Joumal'of a ijuestlon-_beto< studied- la superfluoust:- curaclss that'are beiat published,*' . of Asbestosto Dty Water," the Journal - water," the magarine says. "Galvan- <elatms Real Amarioo, a-spokrsmsn for reported that where as much as 600 m3- - lied Iron- pipe can contribute minor' - Johns-Manrilleln Chicago. "It's trery'- lion fibers per literof an asbestos-lie amounts oftcadmlust lead, and zinc to 1 -torolredsubJeeC" >.-/- mineral were present to.the water, no water^F,VC pipe can release vinyl j V UeCallie pointed out various-sdetw-carcinogenic effects were ippsrenl tf-, chloride monomer. A-Cplpe-. when car- - ' tlDestudles'whlch hare failed to drawa ' 1 terll years. .rytog very sggmslre water, ean lm- t correlation between-stomach cancer..- - Win Canids, a .study ef S towns . put tsbestos to the water. Asphalt of and drinking water. But be admitted,-,, with high concentrations of naturally-, coal tar lined Iron or steel pipe can te-a "Thereto no jurlsdictioo-to the world * occurring asbestos to tbe'water failed lease polynuclear aromatic hydrocar-' and certain!y not to the United States., to reretl any excess cancer attribute-.. bona (PAHs) to-lhe water. All of these^ that limits either the amount of asben-; ble-to the water.- ' are recognized carcinogens."*' tosthatesnbetothewaterortheasbes- ; win Connecticut, e'study funded by The megszlne concluded that the .1 tas [lowing through the pipes." tie Envinmmental Protection Agency `key quest.io..n..t.o...w...h..a..t.le- ve-ls tof chemical. ' , He stressed that the fotraula to de- concluded there were no changes to in termtoeaggresstreness baa "nothing to cidence rates for cancer of the stom do with health/Mt deals with the dura-- ach. coloo or rectum between 19U and hllity ol the pipe-. However, others 1P73 -- even though to 1SS0 A-C pipes contamination are acceptable to drink-. | tog water. The answer? The magaatoe , wrote, "The levels currently to esdst- ctsca arevery acceptable." I ''- CAPCO JEN 0006840 ASBESTOS INTERNATIONAL ASSOCIATION (Limited by Guarantee) 68 GLOUCESTER PLACE, LONDON WxH 3HL MEMORANDUM TO: . . Member Associations FROM: Director General AIA/12/REG 22nd February 1982 Subject: Summary o Main Features of Asbestos/Health Regulations We are enclosing a copy of this schedule which shows the main features of asbestos regulations in countries where knowt) as at 11 February 1982. We would be pleased to hear from any member who feels we have omitted any important items of legislation that would be useful to other members. Enc. CAPCO JEN 0006841 AIA In fo rm a tio n Memorandum Ni AW! 11th Februar* DIP c O H H H Mco ,Col. H JK O H >O cm o MO rl >nHP ft CL *H P5 C *H `NS J8 jN o'9 S race P (0 -PC) > JO c X 0.6 P0 UO >s C ca ou * Uu CL s* 0 H(D Pp PO f--I O fl) *H H o to a ^ Is4J 09 o . CO **4 P a P P o e *o v ^ ^s s X 0 0 U ffl >4aOH* 4E34 CO # * O O ` CO P .jH'H 4- ^ 0o o o *o us" o a a *cJ i T3 000 CpOM0 o e> 0 >4 O L- O Pca p U Ps o* oOprOamH OBJ O H OH HMw OH co p o CCLL3P C o o p < C7H QJ H r- p,p TJ -0 a 0 0 M3 O0 01 o. o C h o0 o0 *3OD-t V,MOt 00OO 0 & <_D C +P0. >O% oX 44 H jaJEQ.f-ul to cn O-^s C 4JZ4 Ol-*XH C4aJ Eo H O (9 *H *0 >us C CL CO . H (4 44 O *H 4- 3 C O *H 44 a *H 43 44 SO 3O , O CL 4- CJ U oa3 a. 5 P0> PP PJO p0 P0 P 0 ft TS No oa M JC 0 a. p *u EACH MEASUREMENT ACCORDING TO THESE THREE METHODS ASBESTOS INTERNATIONAL ASSOCIATION Summary o f Main Featuraa o f Asbeatoa/Hgalth Requlatlon9 0) <or Q. U zU! O a z s l oo<or 4. CO CM *n >H c c .O O a C H o 44 *a .c C 44 U c c H . UE "O a H H 3E at E ox C3OJ to zo 4*04 c O 4H4 43 (4 <*4 44 tn 04- o 44 43 <C O u -a C *t34 H a c o *H 44 Z ou x H -H H au 44 3 :o<-O <H 3 JC X 0.44 O 3 (3 US S Oor cn a cz o E u >% 4. 0.43 >- or (4 =Oo3 4<3C4; . I'.'T O 44 Q 44 oO 44 44 ' 43 43 44 jQ * J3 a 3 4? *o 44 O it o O it o tr\ 3 *H m *H CH'D 1 H I u I H IH O H &r\ H m 43 c rL a. M cn p cn s cn e oi c o co co c P 0 P JQ P S P SH C M C D -C 0 C pPP 0P 0P pva 0 0 o p o p 0 0-- p p O P O P r*> cjh c p c p c I \EOu \EOo PpOo PpOO P OJ OJ 0 0 \6 E p0 e P0 0CLP 0CLP (i- ia 3 n n a o a o pp vTOO^`OOO'O^NO'O^ 0P CO C7V n3 0 p p p 0 3 CAPCO JEN 0006842 5 0a)<uH D 0) M .O .U -P _ 3 W CT3 roQ oC X P CUM H O 01 p -g T3 EM a 5s o >* 4- 4J JQ (4 O c 0 4-3 c n >-t JJ H *H O C o a .w O O a. o -H o 3 CJ JJ ewe .c E XJ ui to a 03 TJ 3^ TJ O O . 5 a Q.XZ -u 3 > TJ >>4J o M^ JJ CL C4J O 3 4- c C jQ XJ o <- H o. m # "O H 4J M rH M M 0) d- X3 *o 3 o Q.XI 3 O 4- C > *H JC e .Q 4- ((-wo ca c3 8 oi) cn c {H o 4- rH H o d- cn a c ccn oc 2w a X 4- 0 C o -h m h a H O "H H O H4i g M >T3 M o co a. o cn tn H Ci) c o JC c o OC -w raw BJ E * co -C **- =*3 5 4J H .P JJ 3 H c < coo TJ O 5 OZ <3 *H 2: -C -J O 4J C M *H OO x: CJ *U -P * .P PO EHu \E O 4- 'sn* *5}I XI 4- ** M O CM XX CM *H 03 4- O C JJ *H CM H C O rH JJ H JJ O *H CU ^a 4J U 4J on *D 3 JJ V 3.H TJ C -O O O0 3 cc *0 H OO O CJ H C M -P 4J MOO <c CJ *H H g.orH ce HO 3 J O 4J Cj C4 O.TJ 3 O M Ui . IO 3 >H CJ o O X X O O Ol O E 2 o M JC *H S x: 4- CJ a CJ '-P cn XON Q (U O M r-t u M M rH* OS a m jo o cn a <C > c r* 'o c > M > TJ o 4) Q.(M -H -H 0 0 O T3 a. rH M M O CO > xi 0 r-t O O M 3X co <Li.li.OM h- -- Ji ffl *3 u CO S5 CM o H 4J lA Q M H OV O CL 4o CO U CM H O 4- CO CM H z o u O TJ > CJ\ Q JT -u Hr~i *ri OH JJ 23 c CJ >nJQ 4- TJ *H Ui O3 C O' or QZ 0- UJ 0 Q. o c >H O U rH "5 JZ 4O tn c3 E *0 \ U 4 T3 CM C -U O JJ 4c O) MC 4- X 4- U H Q> c O H ` H 3 at m MC H --l C a M 0.0 to 4- JJ Sgs .p (H4 3 oe 4J g C? H c *8 a u\ ac4J C O Q C` *JHC C H 4J JJ M JJ x ag O3 *H cn as U U a c e o 03 C TJ O 4 JJ a *o H H O -- XI 4J 4j a) * O oca 2 x> P HO T3 M rH XJ XJ e 4J C TJ 3 OC OO OC 4J XJ U. 5 0 o c JQ O ffla M M M 4- CM lA 3 5* *0 00 CO 0\ JC c o C 4J g 2^^ i-l M 3 O C -P o 2: C X3 d- "C co a O 3 = 4J C 3 1 M 3 3 JT 4J (4 4O- 4UO- TO *H 4J H X3 E O O 4lA 4- J3CHJH*T*OHHJ H3> O U 30 J2 O 3 i-H > lfA-i 4- O CoMJ jJ H-cCHHn Ol CJ TJ O JJ CO CT O C *H Oi*H M ^ O C rH fA TJ fH4 H a. Mw>.mo 3 CJ J3 _i a w TJ CHH 4 W 4-^0 1 --1 5 E a I X) ,OM 3 X) d- cn c S > U 3 O 4OJ --XJ 4 CO 4- I vo <t 4- 4J O 3 _O X3 >>2 M H coo .0 * co .]*-!<* c JJ H *h 0 a 3: fH IA *H 8< W M Kk Q O3 4J OOE M JQ O S-S O _l #dM- d- H O >n4J JJ JO O O <D O 3-JQ On Co dd-- *0 O w t4 "O 4J Q.^g _g xi a..c E -W TJ 3 MOW C4JH H X * O jQ O H X JZ Q TD JJ OJ L M M M CL4oJ cOo O C H*nc o O 4J 0Xi o 4^ X3H O3 4J *o u a JO 3 O cl U W) *H P ooa I CM I a. x 1 H s CM o\ 3 rj >cc o o au TJ a a cC CJ O TJ C rH c H U. CAPCO JEN 0006843 D ra ft regulations completed and awa. p u b lic opinion (expiry date 31.8.81 REMARKS -D> U C VcI >% ><a CwD H .u c 2; - H O 0 o^e a* JaO1 TJJ3 rv +0O)iv*JH3i s4JS x&H f* a sz id o ! J8^ r'- .o < nCO<M*s SUO- *a0H) kn ct cn (4 c a c UP 0(0a*. 0x a> cn f-j ca in a O.JJ eCO --3i 4a3s9o .<(*>- QH o > a "9 *rt-4eocJ E 0) c o 4H4 H3 a 02 44 4OP. X CaO* p ac -T3 pa JjHQ 3 "O (u o o 4pc4 4J *H S.8 3 a .8 5S > THO3O> JZ 44 o a *h 4cu9o --s>Ha> T33 OCJ u a. 4oJ o 3* 4h4 *ad} <c -p tao D> CH o J3Z a h c a *H J= ^ a> * 3 CJ n 0a.4O39 a T3 44 -xM; jj o CO ID 0 Q. p o XJ O <H *h > a 44 .1 C iJE co < a a eg E "O CCM >* 3 op 4Oi .O *a oo ^u. H Pa 5 p < >* C c o * p .2 0 L T> P 44 4HaCoO4H. *Ph--cC3CknL*0rec--3CH4<nw4rh0(aXOC-94llr*TvCO0H3tl LH4*PCauHH9 p cn h tx-ZOL 0> 0o 00H 40H- -C 3 TJ tO 44X44"4tP4i 3O a. 2E O>CPOcHn 4TC43`UcP3On- p O CXT3 OP uH. a oOr 4m4 a: 44 3 CP Ca. o C H C SZ C *H 44 x P O 44 } C iH z Po 3 H O 3 op 44 O o O3 I 4xa4. 0 I Tc> Q CCMO > H 4O4 44 TD .-IVK\JOaS60eQK>vMN4PPCoecs3t (Qo0 44 CCMO c r* CLrH 4OCH4 H-4CH4 3 X0 w0 3 CM uU-l 4H-O0 N0 lx0O- H>O OS <0rsa\f rs 2o P 00 Qo rH OS Hos X *P3CC3O STANDARD CONCENTRATION E lo t 445 "Methods end measures fo r the p ro te c tio n of the workers exposed to asbestos fib re a t work places." REGULATIONS Greece COUNTRY CAPCO JEN 0006844 44 c ~c TO O E H > 44 P *H O HOG 3 > -H O* C -H *H P 44 O H *H C *hoO 44 -H p Q.r-1 CO O c to b"3 (0 44 coc OMo H O o X> H C g -O 0) O (4 in S-i o 0144 g *> c o or H Q> 5< a. n H ^Pi Q0). O X CO c ce z D 0H U O c O ,,U 41 u 0 a "o *00c B r-t O.X*3 3 ^c j>a>M i-l e JqJ . hS4J a sik o. XJi3H 3 o HO P -Jl U O P & o x oi o > _ u -So C,, to (u 44 > O H O O H 0 3 c cn*H g to q.J5 o CO >> " *0 4)^ aP -H P *O8 4xeJ: h 4oJ b JJ Z3 O t* C 01 C U. 4J "H a-s P^* CO 4H4 N a oh a $0 o <c Q.&, p ags44 H P H 1 1H O o <*- to a <-i r-t B 3.S O *H DIE 3 H C C^8- N 3 H <t- 85O *H 0.44 cSVl ZS. 44 SoH ' P CO O 4.O C 44 C 4-1 P 3 H ~ O H -A OH4J POO H E O 44 H 3 C CO OI 3CT4J H P 5-8 OOP a. p xa E O H H 3Z E^ C o C o u u'a *H >>*H *H X -O 44 44 s4aJ cO i C C 09 TO ffl *4 > > COX. jc a p p C (4 t~ a. a. a. B CL a P Oi 0c it c i/\ p 01 o7 c *H C> H O O -C 44 Co 44 o3 44 a 4J TDO C 4*4 O 4> *H PC -85 >* COT) OO ** 4-> xo vo o\ a 4-1 HO 7J to 3p 3 44 O 0 c <* H 3 44 C H O 44 E O S.5 O z 0 - 44 0c a H H *H H H* H pH C 44 TO< 44 O *H or O TO TO H* a *h H TO z >. 0 X0 Ui p 0 C_5 z XP CJ CJ 0c 44 -H a 0 11 44 C 0 r-< C O or e H TOc rH \ E 44 0 E <x O zN CD < L- CM 44 E *H in 04 a <c a CL -P* pH pH 1 H E > U- H Q. 44 pH T3 P O Ch 1 H e >Cfr- 04 o 44 -TO a. a *h <d cr 0 O CO X TO PO -H o oo a 2k 04 >* o 4-> Cw c o a >s O <*44 oN p 44 TO O *3 c 0 Q. O p c o 9" o 44 TO X*H pH H P pH O too c TO P *OH o co 44 p CO cno in =3 Cs| C3 Lad o\ trv o\ > H 4J a 44Ul XS cB a r-i .Q O <-g 44 O o a POO <j\ 44 3 -H C TO C o\ SS3 >> TO 44 E 3 OOP o ZUH V0 o\ pH >s z w ith the recommendations >DC I: o o CAPCO JEN 0006845 REMARKS <0 OXI H U U I 3 f<'d-ho- o 3 C 4- X 0} 44 CO C C C ~ 4J o a to o oh>. a o o C *H 01 49J 8lCO TJ *H BOOH 44 44 44 O M3 JJ CL 3 O 44 m o -h o ' JJ JJ B Q.*H H a co u O CO *H (43 O 3 gs-g"O A *H o 3.4- JJ'EJI Cl CD O '"l O 3 <H U hoc H ffl X M*H o B JJ 4-> o <s O UJ Q. u 09 JJ B E "O -h c ooa y CO CTO . C *H 5? fc-S.- 0) JCt 8x4r!4J 3 "tJ T3 -> HH O U JQ ^J5 4J o cd MJJH a O CD CO CO H O g^i-gs: o CO 3 O x: jz o --t JC * C *H u a TJ C 3 o JO -H 4- C *rt 3 O aa oca xi i-i CO O -H J3H UH BJJ ct3 H O Cu *H O B 0X03 O CL CO CO o P .co< 3 m o. _ 3 ac CO o, a P >% P CL 4-> JC P O -P a c P CD O'O'H n i-c >*O >sJC O O O CO BH U HH3 C 4J <*- C XJ CD CD * oro E o CO CO CD CT CD CO ^ ^ c3H O hH B3XJ C P HOC0X3 0 D>--C CD 44 -,&*h u (4 4J \q u x: BHU JJ C H OJJH *H C E jJ E 4J 3 O h*o-h i3 04^ O a P c e c ao oh 0 0 4- a> p u o *H P CO 3 0X0 ^ CO CTO XI Ol*H Q. u Q. 0 a * *q 13 OP u H -P P x* c 2t E*4 H*D 3 Oo *D CT H P a oca* P o r-t o -h c u- > Oo o UQQ..J--uZ 0*>H-t Q**4HJ CD cn--c --c CHH 4-> c3 OxJ - m H4JH -H c > C * <044 u MO 44 CO * JO -O Cl > 0103 O 8,*H C C 3 3 -- U -H -O CD J3 O O II O H m<l o m b a 4J T) a o Q..Q a fHH *Oo H C o *H 4- CO C4 o 4a4 pSo-Po a. ^ q. 3 ^ a >% H *3 ^ Oo 4-1 Q. O i4 H OH H 4J oH 3o,vo* a.coo a *aH .. 8 O 13 -Q c H c w *c czn - a a< a BBC *o 4J - o Cx*h-c CD op > 4J ID cn Mxaor ub 4--aa>cJH3CCO SB4OI--3C HW >ffl O3 C 31M-- O OIB CL M C a. as Tt -H liJ CL*H X "4Oj 3 H -C a p a. <P CT H C H *H O > 13 H P a a. O C/3 0P *a c 40J1 a -p X r*MH -< \'o <*- o P CM O o JZ 44 0) p C ^ a IeD 44 c O -h a > H B4J O M x: 44 cx a 44 a M M WO x: E (D 44 ID CO -P O X C X3 ffl B--I U CD CO O 4-0030 x CO C C C 0 4- O CD O O TJ Clo HO O 44 O 44 CO E Q. >nb-H CO C C ID CD M B B aB 4J 44 44 *4 >"0 C4 bH H C C CO O 44 o) e 4. m O 3 4- 44 X3 C O -H C CD I OM3 B O <H M Cl u <o 0003 o 44 4. a 4-0 4- H- O +IH CH3 OCT3 t~i f P a >* o -h _ U~~ 3 _ *w o or OJ>4JO^ x: CT h" H CM w U JO -p H H o *u H a o u CJ 4J a a X H iH 1 5 CM I IT I STANDARD CONCENTRATION REGULATIONS *3 u pa 5* o CO 4JrN* ^ xi <t t-* *o-i m * On lA r> ON O P ut a. c x> ^c-1 a M CAPCO JEN 0006846 COUNTRY REMARKS P u hD Cl (0 Ck 3 C 4J O* O CCD O u o at a o o a* p E P p J3 a. 0,*H *H 3 "S H 3 3 a tu 4J 3 or tT o *o C o 44 cr a) >% a p p p . >* a u. o X> w > r-i U X) c c c O. CL omo >* u- X>a *0-.t4jiJb co CO JB O H 3C __ 13 H C-H X> p C o XI 0) E C c too 0o x0i 3o H O O X 6 X> . > > <D >> Sn, " OCB tJ *H O O 4J 44 h u a- -i a s o o a a a. a e jc c -p d a T3 w s a uj *-i a jj G9 H X o ctjz mx o T3 po o c o P P a Z hU CLZ 4J E CL Q.4-) o T3 J*HO P 0O) P Q. O c > /V CO 44 I *H **H I o C H rH O Oo T3 *p Ve* O ^(t- P 3: 4- >o >% CM CM P P 44 4- rH > oa 44 44 p CH (8 P > 3 ,*H 44 QH O O *H 4- C >O<-3( LH. C (C4 >O 44 Po .eO ct 3*C jq Me -h (4 ~JQ < 3 W 3C 44 44 ^4Jh OH on O Se^2o CT 4- C 44 p 3E O O (A Li 0.44 -p O O P *H CO E a. c 4-> 0) O rH *H 3 P JC C P T3 t-- O -H H 3 a* or c > <a H P C P B41-H J3 a> E o 3 <H is to 13 u c c o * oh or H *H O' JJ OX-H Of E H4J o n 3 C DID OJU- C *-H o o jz -h a p 4-> -l *H Q.-H i-l 4J * -t * O P o at jo o CH a E <-i C d) N H a ji u- > cd CO 4J h4J CJ\ NOP rH JC o a> *> p H 0 ft -H O 3 H X 4- O.J= P E 4J a o. a o h C 3 *H a X UI U H 4-> 0) -H J3 c 4J (0 O o >_ o O CD C 1C ffl -o (D P J5 4-1 p a 2 G w 2 i 0 n 4-) 0 3--1 4J a -a i -h > co am H 0) P rH JD Q-*H 3 Q.-U o a a *h 44 P JD P o -H JC J3 J3 4J -U Ct fl <*_ 3 E to C 0 L- ,>< O XI 4- H JC O C XI 3 '> O OVO *H E OH J O P3P 3> a ox <*- m c o H 44 3 r-| cn 3c CT H >s p l-l Q. ct a *h c H P >*.o p Q. 4-1 >< T3 P PP3 a *0 44 T3 C C - C --1 3 H --1 44 CJ P -H \ > o< O < -C co cn o ZD O H H CJT3 ooCP > T3 P e?0 -tn -a C H 44 CT c -- -H --1 C *H Cl H -U oc ca H o pi Q. - 4o4 P O J3 4- 0) a rM *0 rH C a o co O 44 *W 44 0 X3 rH 3 CT 44 CC O 3 *o CO J= P i-- 3 a. CT C 3 *H C P *H O 4- 44 C CT O ca O1 H CO 44 a O 44 3 CT P "U 4J X3 CT CT CT C -H *H P *a o H C 3 44 IP 3 PO 44 OP > P CT CT 44 3 p p *o o X L : I VO STANDARD CONCENTRATION REGULATIONS f. P o ao c <n lA fA M3 r> \N lA co <t A ao z z. 44 x> oo << c o z CM CO ON O3 4J C l"aH or Ux4cc3O4i:t 07 *oH "CLcoP- c h a co 2H: N*- 44 (A C o 44 c p >c c lSlI T3 tn CAPCO JEN 0006847 COUNTRY cn o<cr <D s Co or 0 O 44 H O -t O O0 *o cc 43J TJ H H 4J 0c 0 43 o a 3 H o O ON p o r* CJ On 0H (i- c o c3 p 00 0 43 0 Ol O 0p0 0p P "O 0 r-i 0 ~o *H 3c -0Hy h 44 -> n H C 44 -H o 44 C O H H H 3ET a -H o 4J >. E 00 3 C -P p < o o 3 H O COH-HvO> - 4= "O 44 o Eo oh*JpO",-o-n c 0O P **H a aCa4pi****-i ,0*h o P ho a > H OD_*H, *-4>E. C__ 4a4* jc jt >> >* <r e <*P PP N o _ cnt-- h 44 _ aa 44 jj a u ir c a J3 C4 43 c cf\ H3 H3w< cn*H Oc a ea O CO H C O >a >o o< Eo *H I" 44 C ~4J ucae 44 cn O *rl E a c *h c o 44 44 -W CJ vj c a e o p *a >t44 *H 44 c 44 P 3 44 a o o o * jc 4- Q. h c 44 a p44*HHli) C o o/e aK a > P XJ 44 P CL<I OH > _ 3 43 r4 Of*tf XI L- 3 OO O 44 *4 >. P C O 44 a. 44 3 C a E *o <t- P aScaE *H O 0 IS) E 44 t# * 3 P S*r( X 0 > O C C CL O C O *-l O H UJ U. S O O 0I I I I I H 3 < CJ . di< rfxtotr a. a to ol o 0UU.ZUQ ax 4Z 0 0 TJ 0 H #H 0 j? J>0O TH9 CO 2. (4 OM -X 0 p a> oc 3: O H X &Y 00 3 TJ ^ C0 H O X 0 o at -p c 0H 0 -X 43 P <0 O3 Asbestos Cement. Advisory Committee on Asbestos M illig ra m s per Cubic Metre. z o < 0) or s. uoi -P z s CO QI or < H a z < 5 t/J CM C9 ui cc: a c a f-i >or P N x o CJ 4HJ s CD a 44 *ow-t P> xi o H a *o o0 (4 CT O 4J PC05 a. > 0 CD a xcu u0 CO CO 0 0) >* C 4i 0) H 0 TOJ Ha 3P0) *pH <D I CO CL HIP ca u- JZ NS<t 0 C 4-1 coc a -h H *1 E 44 0 3 H3 i--I 3 P 4J o a H CO lOhHC CO U- S0** >% KN O 0 P O 4-> O CO VOH 0)4J9v rH O 0 3 P $41 O -P (0 > H OCH04(J0O0V jj a o O: H ON o o noo\ Ci_ _C q.co 03 Os o UI S w.H Z K\ 0 PS 43 JD Ol 0 rH E 3 <*- # *U *0 NO P0 3o I 2O OH ID C <0 4-> 0 a 0C H 0 0O (u 0O 3 a u 0 O rOH \ C0 CL >N P a\s C #-H H <*- c0 s024J VO C H 4J | 0 H I IA 0 H 0O p aJ O 00 I cn -P O H 5 ,E H CM 4J C4J OcoO o0 C 43 0 N< 4. A/C --- 5. ACA 6. mg/m^ - Threshold L im it Value. illilitre . Average. Fibres per M Time Weighted H 0 C H04J 0C 4-> #-H O 0 0 *H Q. 0 4J 3X0 op O -tf 4-> O CO NOw >*-H <C -P*CH r* x 4- a to m tj HO tn < A ON H Index o f Abbreviations -- 1. f/m l 2. TWA 3. TLV < LD oitnnr CAPCO JEN 0006848 ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway, Crystal Square 4, Suite 509 Arlington, Virginia 22202 (703) 979-1150 April 14, 1983 Memorandum For: Subject: MEMBERS id Expected Action by OSHA to Lower the Permissible Exposure Limit in the Standard for Exposure to Asbestos Dust Aj This memorandum will be as brief as possible because of its urgency and to minimize time in reading. The U.S. Occupational Safety and Health Administration (OSHA) has re cently announced that it will accelerate the schedule for revision of the permissible exposure limit (PEL) in the current asbestos standard. This information was initially made known to the Association in a meet ing with OSHA Head Thorne Auchter on April 7, 1983 when a recommended standard for occupational asbestos exposure in construction work was delivered to the Agency following extensive coordination with the Building and Construction Trades Department, AFL-CIO staff. Specifi cally, Auchter read a letter to the group that he subsequently signed to George Taylor, director of occupational health and safety, American Federation of Labor and Congress of Industrial Organizations. A copy of Auchter's letter dated April 11, 1983 as well as Taylor's letter of March 11, 1983 are enclosed for your information. The current intentions of OSHA are summarized below: 1. Publish a notice in the Federal Register in. late May or early June 1983 which would announce that a hearing to address primarily the PEL issue will be held in late August 1983 based on OSHA's October 9, 1975 notice of proposed rulemaking. The scope of the 1975 proposal would be expanded to include the construction industry for purposes of PEL. (Note: It will be recalled that OSHA's 1975 proposal would reduce the PEL from 2 f/cc to 0.5 f/cc and the construction industry was excluded.) 2. A final rule establishing a revised PEL will be issued in the Fall of 1983. 3. At the time a final rule with the revised PEL (appli cable to both manufacturing and construction sites) is published, it is planned that a proposal addressing development of special provisions for the construction industry, as well as updating the medical and hygiene provisions of the existing standard, will be issued. CAPCO JEN 0006849 Page 2 As reported at the March directors meeting, and as stated in Auchter's letter to Taylor, OSHA was planning to publish a proposal on the as bestos standard in June 1984 with a final rule to be issued in September 1985. The only discernable reason for OSHA's acceleration of its sche dule is political in nature. The AIA/NA Executive Committee met April 12. This matter was the major agenda item discussed. It was concluded that the Association should, among its initial efforts, urge members to send a letter to appropriate congressmen (particularly those whose districts include plant sites) re questing that they contact OSHA (Auchter). The purpose of such contact would be to request that Auchter reconsider his announced approach to ward resolution of the asbestos issue and proceed in a more balanced and reasonable fashion. A draft letter as a basis for corresponding with members of Congress is enclosed for your consideration. You may wish to add specific informa tion concerning number of employees affected and payroll involved. In any event, your timely attention to this matter is essential. As a related item, the above subject will be a major topic of discussion at the June 7, 1983 meeting of directors. Particulars concerning the June meeting will be forwarded in the near future. Executive Director Enclosures CAPCO JEN 0006850 U.3. Department of Labor 11 APtf jggj 11 RP?.~ Assistant Secretary for Occupational Safety and Health Washington, D>C. 202)0 Mr. George H. R. Taylor Director Department of Occupational Healtn and Safety American federation of LaDor and Congress of Industrial Organizations 815 Sixteenth Street, N.W. Wasnington, D.C. 20o0i> Dear George: 1 want to assure you that I fully agree with you that revision of tne asoestos standard is a' project which deserves high prior ity, Personally, I am very concerned about the asbestos problem. My staff has oriefed me on Dr. Selikoff's report to which you referred in your recent latter. In addition, I recently met wicn Dr. Salikoff to discuss asbestos and will be talking with him furtner. I haye spent a fair amount of time lately with my senior health staff discussing asbestos. In your letter of March 11, you asked why OSHA did not release the draft of its risk assessment for asbestos until very recently. In fact, OShA published the numerical results of the analysis, the num bers wnich you quoted, in a Federal Register notice on January 13, 1932, only a few montns after the draft was completed. This gave the public notice of the risk as we viewed it. The draft released more recently was considered by us to be an internal document, neither sufficiently polished nor complete enougn for release to the public. A senior staff member within the Directorate of Healtn Standards (HSP) is currently revising the document and the new version will be published as soon as it is completed. We do not expect any significant changes in the estimate of the risk to result from this revision. I agree with your criticism of the previous administration's lack of action on this issue. In contrast, once this administration had the beginnings of a regulatory agenda underway, last spring, one-year ago, we created a preliminary regulatory development tea.ii to review the need for ana develop recommendations concern ing revision of the asbestos standard. The team includes members of our HSP staff, economists from our Office of Regulatory Analysis ana an attorney from the Office of the Solicitor of Laoor. Sir.us formation, this team has prepared three documents for my or'-lc=, a Research and Analysis Plan, an Assistant Secretary's Su..-and an Action Recommendation. Tne Action Recommendation was coi.plcted Feoruary 23. Tne recommendation was made tnat the stanjcrci Oc reviseo in its entirety, with revision of the PEL one of the wost important tasks. Tne principal dates in the plan proposed in tne Action Recommendation were: CAPCO JEN 0006851 -2- Publication of rtotice of Proposed Rulemaking: June 1984 Publication of Final Rule: September 1985 * Because of the very serious nature of the hazards presented by exposure to asbestos, I have decided to accelerate this schedule. Accordingly, we will publish a notice this summer scheduling a hearing oasea upon the 1975 notice of proposed rulemaking. We will update the 1975 notice to discuss risk assessment and significance of risk issues. We also plan to expand the scope of the proposal to include the construction industry. Reduction of the permissible exposure limit would be the primary issue of this rulemaking ana a final rule on that issue would be promulgated in the Fall of tnis year. At the same time wa publish that final rule, we plan publicatioh of a proposal.addressing development of special provisions for the construction industry, as well as upoating the medical and hygiene provisions of the existing standaro. I have asked the heads of OSHA's Directorates of Health Standards Programs and Technical Support, Leonard Vance and Edward Baier, to meet with you and/or members of your staff to discuss, both generally and in detail, the timetables and technical details involved in revising the standard. Of course, I am always availaole to meet with you as well. Indeed, OSHA staff already have met with Roy Steinfurth, the administrator of the Asbestos Worker's Health Hazard Program, to discuss the standard. Further, as I mentioned earlier, I nave personally met with Irving Selikoff on the issue, and have scheduled a meeting with him and members of my senior staff in the very near future. I think it is clear from the above that OSHA intends to act quickly on this issue and, as we do on other issues, involve Labor extensively and substantively in the process. I look forward to working with you on this very important standard. Tnorne G. Auchter Assiscant Secretary CAPCO JEN 0006852 American Federation of Labor and Congress of Industrial Organizations 616 Sixteenth Street. N.W Washington. D.C. 20005 (202; 637-5000 executive council - LAME KIRKLAND PRESIDENT THOMAS R. DONAHUE SECRETARY-TREASURER Joftft H. Lyons S. Frtnfc IUft*<y AlMrt S!>nl>tr JE.CCm. T*aurTn#H* nJ#jr KMWittn 7. Bttytoeii H. V^jmn Warn# E. Gtnn JoyC# 0 M*n#r Frame Drart RicnarO L KiUoy Thorraa W. G(ason Ma/tm J. Ware G*enn t Waits anfls-o Fesso Lloyd Mebrieo Alytn E. Heaps John J O*Donn#tl Rodar: F. Goss John J, Sr*0*y James E. Ha*fti<f Vmcent ft Sombrotio Frederic* 0`Naal Murray n Finley SColal rCies >t Pius'? Cav.c 2 F:?5--aor.se Wm. W. V*Wtr ;* Jsim O^Zofteint Wdiiam senytia Douptas A. Pnir' Barbara t*ots*.ns3n Gars.O V*. usEmee March 11, 1983 Mr. Thome G. Auchter Assistant Secretary Occupational Safety and Health Administration U.S. Department of Labor 2C0 Constitution Avenue, N.W. Washington, D.C. 20210 Dear Thorne: During the recent court case on ethylene oxide before the U.S. Court of Appeals for the District of Columbia, OSHA released as part of its case a paper entitled "Preliminary Pd.sk Assessment for Asbestos." This document shows that workers exposed to current permissible levels for asbestos are at high risk of dying from lung and other kinds of cancers. It points out that as many as 8-260/1000 workers exposed over a working lifetime to levels at the current standard may die from asbestos related lung cancers. Sven at reduced levels of exposure (0.5 fibers/cc and 0.1 fibers/cc) the assessment predicts significant levels of risk for deaths from lung cancers and other cancers. Thus, --^77 many thousands of the more than 2 million workers exposed to asbestos at or below the w standard will die of asbestos-related diseases in the coming years. --a-* The asbestos risk assessment was prepared by the agency in August, 1981. Nevertheless, for a year and a half it was -withheld frm the public until it surfaced in the ethylene oxide case. Contrast this silence with the zeal msplayed by the Agency^Tn~CS.lling *7 attention 'to studies by industry tending to downplay the effects of toxic materials | on workers, and factoring them into its health standards review process. A In the ethylene oxide case, OSHA's counsel for appellate litigation told the D.C. Court of Appeals that rulemaking on asbestos "admittedly hasn't gotten off the ground..." With the attention of Congress and the public presently focused on the enormity of the asbestos problem from past exposure and associated costs of compensation and third party law suits, the AFL-CIO finds this admission, plus OSHA's withholding of important information assessing the excessive risks of workers to asbestos-induced cancers, both incredible and irresponsible. There is something dreadfully wrong with OSHA when its program embodies no new initiatives on health standards, rejects petitions requesting.accelerated rule-making or. unstandardized toxic substances threatening the lives and health of workers, and allows the weeds to grow up and obscure the asbestos problem. Indeed, OSHA has deployed its limited resources in an all-out campaign to weaken existing health standards in order to make them more acceptable to the business community. CAPCO JEN 0006853 Xou may be aware that the Congress, in the course of passing the Occupational Safety and Health Act of 1970, called special attention to the widespread infection of workers from occupational exposure to asbestos, rt... another material that destroys the lives of workers..." Although its effects had been known for 40 years nothing had been done about it. OSHA at that time did not act on its own to respond to the Congress, but reacted affirmatively to a petition by the Industrial Union Department (AFL-CIO) and promul gated the Agency's first occupational health standard on asbestos. The 1972 standard which established an ititial level of 5 fibers/cc, to be lowered to 2 fibers/cc in 1976, was based on the British standard and addressed only the risk of asbestosis. The risks of lung cancer, mesotheloma and other cancers were not addressed by the standard. Even at the time of the promulgation of the original asbestos standard in 1972, evidence was available indicating that the risks from asbestos exposure were far greater than risks considered by the standard. And since that time additional, evidence on cancer ___ risks and the risk of developing asbestosiB have confirmed that the current 2 fibers/cc 1 is grossly inadequate. Under previous administrations, OSHA initiated but failed to complete action to strengthen the asbestos standard. In October 1975, the Agency issued a notice of proposed rule-making to lower the asbestos standard to 0.5/cc. Information was gathered but no hearings were conducted, and the standard remained unchanged. Tn the fall of 1979, a joint NIOSH/OSHA committee was formed to review the updated scientific information concerning asbestos-related disease and to assess the adequacy of the OSHA 2 fiber/cc standard. The committee report issued in November 1980 recommended a significant reduction in the permissible exposure limit for asbestos: "Given the inadequacy of the current 2,000,000-fiber standard the committee urges that a new occupational standard be promul gated which is designed to eliminate non-essential asbestos exposures, and which requires the substitution of less hazardous and suitable alternatives where they exist. Where asbestos exposure cannot be eliminated, they must be controlled to the lowest level possible. A significant consideration in establish ing a permissible exposure limit should be the lowest level of exposure detectable using currently available analytical techniques. At present this level would be 100,000 fibers greater than 5 um in length per cubic meter averaged over an 8-hour workday." yy 1 ^ 'V , ^/T As a result of these findings, in 1980 OSHA followed its decision to revise its asbestos standard by publication of an advance notice of proposed rule-making. The {LNPR) was scheduled for the 4th quarter of FI 1981. Unfortunately, with ths-changa in administration regulatory action on asbestos ceased. The 4th quarter FI 1981 deadline for an~'a~sbestos-ftNPK"was not-met?---Nor-wao a--3rd quarter FI 1982 target deadline established in January 1982 by your administration. Even though the asbestos standard was approved as an item for review and updating in OSHA Regulatory Agendas and the Calendar of Federal Regulations during 1981 and 1982, there has been no perce*pptatibble action by the agency to reduce the asbestos standard. CAPCO JEN 0006854 -3- Given the high level of ri3k and,,-danger posed by the current asbestos standard, it3 revision must be a top priority for OSHA and the AFL-CIO so urges. The agency must *-move expeditiously fco~implemenlr-the1 findings of the joint OSHA/NIOSH workgroup to reduce significantly the permissible exposure limit for the substance. The publica tion in June, 1982 of the study for the U.S. Department of Labor prepared hr Dr. Irving Selikoff of the Mt. Sinai Hospital estimated that there are presently 8,20< annual excess cancer deaths from asbestos exposure, and that this number of death! will peak at about 9,700 during the 1990's. OSHA must move to protect workers presently exposed or this toll will go unabated into the next centuxy. The AFL-CIO desires the following information: 1. Why OSHA failed to release its 1981 Preliminary Risk Assessment for Asbestos for l years? 2. What action ha3 OSHA taken during the past two years to revise the asbestos standard (initiation/'completion of an advance notice or notice of proposed rule-making? initiation/completion of a regulatory impact assessment) etc? 3 What is the agency's timetable for the promulgation of a final revised asbestos standard? Ve would appreciate an early reply to this letter. Director Department of Occupational Safety and Health GT:bl opeiu 2 afl-cio CAPCO JEN 0006855 DRAFT LETTER (date) The Honorable U.S. House of Representatives Washington, D.C. 20515 Dear Mr.. : This letter concerns a matter of some importance since it relates to a prospective action by the U.S. Occupational Safety and Health Ad ministration (OSHA) which affects directly our company. We feel that a recently announced initiative by OSHA, as described below, is ill conceived and is being taken solely for self-serving and political reasons. Specifically, OSHA has made it known in a letter dated April 11, 1983 to the American Federation of Labor and Congress of Industrial Organi zations (AFL-CIO), which has been made public, that the Agency's plans for further regulation on occupational exposure to asbestos have been accelerated significantly. The generalized reason given by OSHA Head Thorne Auchter is "because of the very serious nature of the hazards presented by exposure to asbestos." Rather than publishing a proposed rule in June 1984 and a final rule in September 1985, as previously stated, OSHA now plans to schedule a hearing in August 1983 based on a proposal which was issued by the Agency on October 9, 1975. It appears questionable at best for OSHA to commence rulemaking action on a proposal that is almost eight years old as well as is the public record which was filed in response to that proposal. Basically, my company feels that OSHA's sudden disregard CAPCO JEN 0006856 I Page 2 of a previously announced orderly approach and' its' rush into a hearing four months hence without giving due consideration to the current status of all^aspects of the asbestos issue (medical, technological, economic, risk, etc.) is patently irresponsible. I wish to emphasize that resolution of the long outstanding regulatory initiative on as bestos by OSHA should be accomplished, but not in such an arbitrary and illogical manner. You should know that, coincidently to learning of OSHA's intended action described above, the Asbestos Information Association/North America (AIA/NA)'which represents producers and users of asbestos in North America submitted to OSHA on April 7, 1983 a recommended standard for occupational asbestos exposure in construction. Development of this recommendation was accomplished in coordination with organized labor representatives. Both industry and labor, as well as OSHA, have long recognized that fixed-site regulatory requirements are ineffective and impractical for construction which is typically characterized by small, transient employers, high employee turnover, and outdoor work activities the nature and sites of which are continually changing. These problems have made the current asbestos standard virtually un enforceable for construction job sites with the consequence that many millions of potentially exposed workers are deprived of the health protection provided to the far smaller number of workers (less than 20,000) who work in asbestos product plants. Because this problem de mands immediate attention, AIA/NA has placed top priority on the de velopment of an alternative approach that would provide greater health protection to construction workers while assuring users that asbestos products can be safely installed and used. CAPCO JEN 0006857 Page 3 AIA/NA recommended to OSHA, and my company strongly supports, that the Agency's first order of business on asbestos should be to pub- . lish a proposed standard for the construction industry. Reevaluation of OSHA's general industry standard should proceed in an orderly way to ensure that the current status of the industry (as contrasted to that which existed in 1975) and other relevant information are fully considered. In regard to the latter comment, both the Province of Ontario and the United Kingdom will be completing studies on asbestos regulatory issues later this year. The reports issued by these two governments will contain comprehensive data on the asbestos-health relationship which were developed following full 'participation by many international experts. For example, the Ontario Royal Commission on Matters of Health and Safety Arising from the Use of Asbestos is presently com piling its final report based on the testimony of experts from the international scientific community who were subject to cross examina tion by both industry and labor groups. These reports relate directly to permissible exposure limits for workers exposed to asbestos dust, the matter of primary interest to OSHA. In view of the above, it would be greatly appreciated if you would con tact Mr. Auchter on an urgent basis and prevail upon him to abandon his recently announced plan for resolving the asbestos issue and pro- ceed in such a way that would be of greatest benefit to all concerned (workers, government, society and industry). Thank you in advance for your efforts on our behalf. I look forward to receiving your reply. Sincerely, CAPCO JEN 0006858 IK h AUSTIN c 4R F BACHMAYER BRIG . D B KAPOOR c MR D BOUIGE MR M CABRERA . MR R CAIRNS c MR L CEJUDO ALVA MR P G COZZI MR M EYRIES MR E HVID HANSEN MR A SHARON MR B MOHR MR F MONTERO MR A NIELSEN MR W PENNEY MR B J PIGG - AIA/NA MR G SCHMIDT MR R SCHWARZ MR M TANABE MR B TAYLOR MR G TRUEDSON MR H VANHERLE i TELEX NO: AIA/16B 3 APRIL 1984 ( ILO CODE OF PRACTICE ON ASBESTOS rl J f M M f I) I ! M I I ! f M ! f M f f M f ? C 1. THE ILO SECRETARIAT HAS APROACHED MR EMILIO COSTA ASKING HIM IF HE COULD LET THEM HAVE ANY BLACK AND WHITE OR COLOUR PHOTOGRAPHS ( FOR POSSIBLE.REPRODUCTION ON THE COVER OF THE FORTHCOMING ILO CODE OF PRACTICE /SAFETY IN THE USE OF ASBESTOS'. ( 2. ILO FEEL THAT THE COVER SHOULD APROACH THE SUBJECT POSITIVELY AND DYNAMICALLY'AND PERHAPS SHOW A PARTICULAR FACTORY IN WHICH TECHNICAL CONTROL MEASURES HAVE BEEN INTRODUCED TO MAKE THE ( HANDLING OF ASBESTOS SAFER. 3. HOWEVER THEY ARE HAPPY TO CONSIDER ANY OTHER SUGGESTIONS INDUSTRY { MIGHT HAVE. THIS IS A MOST HELPFUL AND COOPERATIVE ATTITUDE. 4. THEY ASK FOR A NON-EXCLUSIVE WORLD LICENCE TO REPRODUCE THE i PHOTOGRAPH WHICH THEY CHOOSE AND WOULD LIKE TO KNOW THE CREDIT LINE TO.BE USED. 5. THE CODE WIL BE PUBLISHED IN ENGLISH, FRENCH AND SPANISH. 6. MR COSTA HAS THANKED THE ILO AND SAID THAT HE HAS REFERRED THE { MATTER TO AIA IN ORDER TO GET A WIDER SELECTION OF PHOTOTGRAPHS FOR ILO TO SEE. ( 7. THIS IS AN EXCELENT OPPORTUNITY FOR INDUSTRY TO CROWN A SUCCESSFUL TEXT WITH A POSITIVE COVER AND I DO ASK YOU PLEASE TO RESPOND. ( 8. SINCE TIME IS SHORT WOULD YOU PLEASE SEND PHOTOS DIRECT TO ILO AND PLEASE NOTE THE TWO REQUESTS AT PARA 4 ABOVE. ( , 9. I WILL INFORM ILO WHAT AIA IS DIONG AND THAT HOPEFULLY PICTURES WILL BE ARRIVING SOON. 10. PLEASE SEND TOJMR R S KIRKMAN C. CHIEF OF BOOK PUBLISHING SECTION EDITORIAL AND DOCUMENT SERVICES DEPARTMENT ILO <. GENEVA SWITZERLAND ( KIND REGARDS JIM STACK IYQI INTA G 298613 INTA G CAPCO JEN 0006859 < < < ( ( ( ( ( ( ( ( c t ff c ( for375,000 in Industry^ By BEN A. FBANXUN WASHINGTON, April ---Tt* gaa Administration today proposal a bigredaction in the amountof*ibcto of tb* foderetlon'* .trades d ;-? Federal'scadSes efthes partment, said, "We would he eery -IpfCf^ OOVCVCVi flCVV wBM Bm QKRf nappy with the leva! of 0J fibara, but' we art stm saying we want 011-" . Ha died studies by the Federal safety agency that showed that even at the 0.1*fibereapoaure feed there would sands of othar groups of wastes worn, even more highly expoewLAccording totbesafetyagency,thosemastatrisk, i ... that is exposed toss manyas 29 fibers agtr of asbestoe a cubic cmtimeter of sir* afasaaaMM88sa^gbe three excess cancerdeaths for1,000 S pennittad in workplace*.^:'.; ... Tb* proposal by tbe Labor Depart ment'* Occupational Safety and Health Administration, which is to ba pub QSH^^oMWCPS''? /T^npJF-sSo^j'i ...m........twS-*--.-i, '^ _a lished Tuesday la the Federal Regis* ter, would, affect 375,000 industrial workers. -; - '' * ' ersZ(Lhoice& -ivAS It would cut the permissible sure teval from 2 fibers of asbest____ each cubic, centimeter ~of workplace the stricter air, which has been tbe Federal stand* ard since 1970, to either 0.3 or0.2 fibers for a cubic centimeter.\l The final choice between me two levels, among otheroptima ofa highly technical nature, are to be made later this yearalter a 60-day period in which Sttjj'RcporlerWTiiti.VV*ix StSfct 2M,6o(l-'flbeiffe<p65ure leveLifltadopts the 500^00-fiberJimiL Employers wouldn't have .WASHINGTOrr-fThe Labor Department, wca^i^ttfcft^'rangeofcnnipllance uncertain how much It should tlghtenocciK measuresu^esposure reachedSOO.OOO fi- pational-exposure limits fo.asbeslos;;fs NrJttaddfU<^ the safety agency will receive written "separi^hSli^S'ruli'fbr- the'wnstmci The detriment's Occupat,tloionn.aaIlISafety Indus^;partli^tit6l6i. intoi'account and: Health Administration is tryingtode transiaitiimture.'<d.stick worl^;^^'- cide' whether it should set maxdimum wWoOrrkX:* ^.llMT^tJ6* tI^f^iVfieV*il3rHa1 w^mninGn3r^.'f:tersfltmlmnattners aal bc ^ After aworking lifetime of expesur^gft place exposure for asbestos at 500,000 fibers a cubic meter of air or at 200,000 fibers a cui `37Vl^tt^OT3d3s?are'. e^osed, to & besto6'indbn{t49;00(i'exposed at above the ' the safety agency-said,- the curremi'1- bfe-meter. The current level is twn million soo.oofrfitj^lev^'sndc'-l.doo/at' above the standard would result in Si more can fibers* The proposal had. been expected. As TOO.OOOflberlevel but befow the 500,000-fiber cer deaths per thousand workers ***n would occur among a thousand people not exposed to asbestos. The standardi.c,.'.,:---.,. of 0.5 fibers per cubic centimeterwould result in 17additional cancer deaths for ' " 1.000- workers, the agency said;1 and bestos has been linked to cancer and respi ratory diseases^.- - - .jf, OSHA. officials aren't- sure whether,ail .employers could measure such minute:air concentrations as the-200,000-fiber level.The leveLLcwei1ngexposureUmlts"wltl reduce the riskpfcfeat&forwbrkers expos^ to as- bestos by-atfea^T?!^" saidPatrick IVsoo. OSHA'i d^^cfife^febestos Is used in' repair, ship; T` there would be 7 more-cancer deaths White House Budget Office, found that there .iHdfiinSg^^JS^n^iia^ibiistntcaonstls ' for 1,000. workers at the level of 0.2 wouM.be-little cost differences for compll* fibers per cubic cenamejer.--v.-jit$"ip?- ancej.witfi'Tohe level- or;the. otheri&jpj.^^ The formal publication of the asbee* $ tos proposal comes wweek after the -f` resignationofThonit'G.Auditoraa the Administrator, of tbw agvncy. Mr. ^jSccnrding. toa subsequent OSHAfahaljfc usinig'.respirators to,reduceexposure^ 'tteSOOjOOd-fiber. Ievel would cost employer* Auchter was a Reaj k v" ^"^milHoii Initially and more than JSSt 5Last:montl^ struck down A (em-sfrS ^occupational 'expo-%# ' . asbestos i` ,,yfdif towering th , ,, Hmi^ineter of airiV* ing prb-{ appointee who was "muilly? compared Withmore. thap by labor unions-, of ife^'talttal'coiiJirh'ntH almost^' tkmal health and safety tfiifth tFMtfr v-^-Tv .-, S Last November Mr* Awfatec tried.* put into effect the OJ-fiberstam an emeigney regulation, but I bestoe industry sued ' IOTBt^cfii. to'curbinf'workplace asbestds^ block it,.'... .expaotr^ While a single limit likely .willbe Tbe enuageacyregulation was turnedon March 7 by thrUnited! Circuit Court of Appeals for-tbeI Circuit. Tbe court questioned the eminent's data submitted'to back its cfolmcfo <-ij;v7-^.S:^rvgifr. '" V>~ ~ Askedtoday forhisview of the safety S^'one agency official said the rulemtakwp ^WCcedurg: will- consider whether "to 'SHrtdisthSction for (different) fiber. . _ .o?asbest6$" Some scientists suspectceitairt typfeje fimy, be more-likely than-others.-to cat^mfsbthelioma, a cancer of the ilnin,~ ... ItPPfJOURNAL S' ?ApriFiI(tel984 A- agency'snew proposal forapermanent standard as low as 0JX fibers * eu centimeter, B. J.Pigg, tbe bend of Asbestos Information Association;' industry group which sued to bfock emergency, rule,Tsaid:'."We havel &?AnOSHA spokesman said the agency ml Si/.SSr: ageeptcornments on its'iatest proposalimtl! May Z5 and begin public hearings-JunitlSi' m&r ^'Whatever exposure.limit is chosen,-the ;0SHA proposal would require^employers to plansfor further litigation.*^-- teach workers about the health effects oFas; ImpriestMe to MeeffvsiVrL.-'. But at the safetyagency's bearing set for June sodation would oppose 0.2 fibers sa "impossible to meet-" bestos, proper use of respirators, and proper v work practices for handling the substance.- The current standard, set in 1975; doesn't mandate any training, although most other OSHA health rules do. "Tbe industry will oppose purring itt people in respirators eight hours day," Mr. Pig* said. OSHA is also considering a requirement, `: y ' - < that employers take some protective steps. CAPCO JEN 0006860  ceptthe OS The Labor Department said yea-" work to block adopdotr of tba-i terday- that it will set a tougher fiber limit--the first choice of labels, hr-a jurii^ work-place standard for asbestos this and consumer groups.. V posed#^'-'-, J year to protect an estimated 375,000 The Environmental'' Protection/ ' Tha: agency*that tifir industrial workers from the cancer' causing agent. But the Occupational Safety and Health Administration said it wouldn't decide how stringent the n6w standard will be until it re viewed public comments, which will be accepted until May 25, and con ducted public hearings slated to begin June 19. OSKA said it is trying to decide whether the maximum work-place exposure limit for asbestos should be lowered to 0.5 or 0.2 fibers for each cubic centimeter of air. The current level is 2 fibers per cubic centimeter of air.. The Asbestos Information Asso ciation, an industry group, success fully blocked OSHA from adopting . Agency also has moved to reduce.-, number of additioriatcancer death* worker exposure to airborne ashes- would drop to 17 p51'OOttworic* tos, which can settle deep in the if, the 0.5 staixlanf were adopt lungsand cause severe illnesses, in- and to seven per X00C if th 0 eluding cancer, sometimes as !on^ as- fiber standard wen adoptedS^'^ 40 yearsafter exposure. - . OSHA said that about 49,C00 U._. EPA has published in final form a--., workers are now exposed aKjve th* number of rides under the Clean Air . ft5 fiber level. *,*; Act that were invalidated by the Su- One-way tefproteet workers is by preme Court in 1978 for technical requiring them to wear respirators, reasons. Among other things, the .; It would cost the industry about $68: rules prohibit workers doing, demo- - million initially and more than $53 litton work from throwing asbestos.; million annually to provide respira- to.the ground or to a lower fioor.;';v tors if the 05 fiber standard were' They also require workers to keep:.;'adopted, OSHA' said. The cost for asbestos wet until it is removed from ;y-r .tha 0l2 fiber standard would be $63 the worksite. million initially and $56 million a Asbestos is used to manufacture vyeru^tiiereafter^. the agency es^j||j|j ing, construction, auto" repair, ship building and ship repair, but OSHA said the workers that are'most heavf an emergency regulation last year ly exposed are demolition, workers that would have lowered the expo and dry wall removers.. sure limit to the 0.5 fiber leveL ' Under the current-2 fiber expo-' Since then, there has been spec- sure level, OSHA said there were 64 / i ;*- - ' , vV . - - '-."/'pPT:T . V'. . 5 k . : ;r*... ~ ` 1 -. '* :. *-- 1 - ' r'* "/ ` UjisV' CAPCO JEN 0006861