Document QXe2ZED405vXzXoG9G0GNbOx4

FILE NAME Manville JMA DATE 1972 DOC JMA002 DOCUMENT DESCRIPTION Arthur D. Little Report to OSHA ANDARD OR SBESTOS \ 4 fret Report to NITED VIATES DEPARTMENT OF AGOR Le to . gry. web ata a irce Mey cape 8 eee Tne hey Staen aithaate shld Sera wea Anela t Ueperr4 - 46 Was eG a oa 7 any MIEST MIEST SUMMARY STRODUCTION Jiver AD PROME ACTORS ACTORS INFLUENCING 1 Marae. /+ ee EMALICS .. i. CONSTRAINTS ON THE IMPLEMENTATION IMPLEMENTATION OF STANDARDS ACCURACY OF MEASUREMENT Le. ~fi AVAILABILITY OF SKILLED PERSONNEL PRAC 2 LACK OF WORK PRAC CE STANDARDS tia IN wee J TIME LACK OF DATA ON SMALL BUSINESSES EXPOSURE CONTROL STANDARDS STANDARDS 7 ENEFITS OM ASBESTOS INDUSTRY INDUSTRY CATEGORIES STUDIED a. 1 CONOMIC MPACT ON 34 ew4 ewe6 s ce TEPAIP MANUFACTURERS i SCONOMIC IMPACT ON SCONOMIC we , PPLICATORS PPLICATORS STANDS ADS oes ADS NFLIGIONS THER NFLIGIONS NFLIGIONS NFLIGIONS NFLIGIONS NFLIGIONS POR POR THER STANDS Caw 3 Rece & ytr . por ry Noes Fe ee? es i i a soar va rimsted Time to Meet Standards ny [ wam Nelared Disease Status of 100 WorkeIN Vices Morbidity and Mortality at the 2nd . ' Testo xxxposure xxxposure to Asbestos 3 1971 Sales of Containing Products t 3 3 j : Private Shipbuilding Panel Estimates of Dollar 4 4 Cost for Compliance with Standards .9 3 Private Shipyards Median Panel Estimates of Possible Resource Allocations for Compliance 31 $ Manufacturing Panel Estimates of Dollar Cost for Compliance with Standards cost increment per worker industry segment 35 ^ sbestos Industry Median Panel Estimates of Possible Resource Allocation for Compliance Lanter 5 Hising Hising we ete 2 Se ~ at BoteaS anda anda PHS a a= a 9*# fining fining sultso sultso Je a af H a a a 4 : : ws 7 - wt 2 r } a 4 - ed eee 7ras aR ada aTan ar acturi ng, # & oa eA<4 Ae rt aS En 4 * as tefol Tt mE aed Mm eos me nore a Riatng 2220 ve q a ay 2 te Paua M4 w Fa)tx) , at +4 14 ra) , | so xi 1 we > -aiLoya Os , ~4 > % af 4 PU PU Bo] > > PE, . Sh Meats . Soe a ae oBoenes Tee eSig noe ns wiper ation larry larry 1. icward icward 7JUSTUSE 70035 code 2% eta Tajanm ~ Eh 50171 50171 os LEo TIMIN TIMIN td Tha .. veners jouse D nale orpor QUILEY f f Daugndrill Egalia Nuclear Shipbuilding 1. Samuel Stratton Ingalls Nuclear Shipbuilding i, cb. ones 0017PT 0017PT pan <Anpany + upud all eth Alder 70Z Soba.Roe : " ws Se nen 1 -. young awl ap aeud.. leh OO a eet 2 3rford pat 700078 700078 700078 700078 ob - _ 11 11 . . 2 _ 2 j ae et } ren . Asbestos Industry John L. Rainsy American Asbestos Textile Corporation W. H. Beasley Cement Asbestos Products Company A. E. Alpine Cartain Products Corporation W. Fassuliotis GAF Corporation Alex Kusmuk Mechanical Rubber Garlock Inc. Division Frank H. Zimmerman Gold Bond Building Products Division of National Gypsum Company ) E. C. Bratt H. K. Porter Company Inc. Edmund M. Fannar Manville Corporation William 3. Reitza Manville Corporation Charles A. Neumann Kentile Floors Inc. Guy G. Gabrialson Jr. Nicolet Industries Inc. John H. Marsh Manhattan Inc. Health Panel E. A. Gaensler joston University School of Medicine Thomas H. Davison A.D. Manville Corporation Vi 106 ArtD h Littu le ir nc Health Panel continued J. C. McDonald D. McGill University Lewis J. Cralley National Institute of Occupational Safety and Health Howard Ayer National Institute of Occupational Safety and Health George W. Wright M.D. St. Luke's Hospital and Western Reserve University Hana Waill M.D. Tulane University School of Medicine W. Clark Cooper M.D. University of California Berkeley Philip Enterline University of Pittsburgh CDR Sam Barboo MSC USN U. S. Navy I. J. Salakoff M.D. Mt. Sinai School of Medicine ArtD h Littu le r Inc. EXECUTIVE SUMMARY This study was undertaken to identify the impact of proposed standaros for nabestos Data were obtained from a variety of sources Cross- checked and interpreted in terms of potential benefits to workers and costs to industry Attention was also given to the expected effect of proposed alternative standards on shipbuilding the principal Federal impact area on the regions of the country most likely to be affected Major findings are included here along with conclusions Separate contain data and descriptions of the methods employed appendices CONCLUSIONS 1 Reduction of the exposure of workers to asbestos dust from present levels to fibers will significantly reduce asbestos diseases and achieve more than 99 of the benefits attainable from the control of dust levels 2 Capital and operating costs for meeting a fiber standard represent important addad costs to an industry that has a low rate of return on investment Although the ability to absorb or pass on these costs is marginal it seems likely that only the textile industry will find it difficult to continue operations board ship repair will be severely curtailed if the fiber level is enforced in this working enviroment 3 A fiber standard if uniformly enforced would require capital investment on the part of industry that is at least twice that required to meet the fiber standard Capital requirements are very probably more period Increased than the industry can meet within a operating costs reflected in higher 1 year unit prices ; 108 Arthur D Little inc will intensify foreign competition The textile industry will be forced to shut down workers in manufacturing along with those in application activities will be affected adversely by increased costs and some operational downa Shipbuilding costs will increase but the major impact will fall on repair operations It will not be possible to achieve a fiber level in board repair in private yards at any cost within the next two years Strict enforcement here will certainly lead to intensified foreign com petition and possibly to the reduction of an important capability Navy yards face equally difficult problems and costly solutions in attempting to meet chin level The major impact of the standard will occur in the following states New Jersey Pennsylvania North Carolina South Carolina California Illinois Ohio Cornecticut and Massachusetts 4 In view of the strong expectation that a fiber level will have an conomic impact at least twice that of a fiber standard appears to be effective at this time 5 Adopting a fiber standard now will result in major benefits and produce the experience that may reveal if revieved within 30 months that a fiber standard can be achieved with an impact considerably less than is now believed and more precisely known than is possible at present On the other hand serious economic consequences can de expected throughout all segments of this industry unless the cost of compliance with recommended asbestos dust exposure levels can spread over a longer time period particularly the textile and ship conversion operations ? * 109 Arthur D Little Inc. I. INTRODUCTION STUDY SCOPE AND APPROACH Arthur D. Little Inc. ADL was retained by the U. S. Department of Labor to assess the impact of the proposed Occupational Safety and Realth Administration OSBA standard for asbestos The impact was to be evaluated in terms of benefits and costs to both Federal and Federal activities We were also to develop apply and evaluate techniques for use in subsequent impact determinations To provide an intensive study that would meet the OSBA deadline an interdisciplinary team of professionals was formed with access to other specialists The team included a representative of OSHA who was directly involved throughout the work the participating A^ L staff included individuals experienced in techniques such as the DELPHI process and its extensions technical personnel who have worked with the materials studied and industry emparts miliar with the production methods for manufacturing them Working closely with industry manufacturers applicators and private shipyards and the various unions directly involved the team identified panels of personnel with appropriate expertise and sought their responses to a series of questions regarding control of the asbestos hazard and the costs and benefits of alternative 110 ArtD h Littu le Ir nc. tandards the following groups These panels represented for determining 1 The medical and bealth professious benefits 1or de costes. 8 The asbestos industry for determining costs 3 Private shipbuilding and ship repair for determing costs 4 U. 5. Navy shipyards was chosen because of Shipbuilding and the continuing need to replace and repair and also because it is the heavy use of asbestos in ships this material in ship maintenance the chief Federal impact area were supplemented and checked by a The responses of the panelists visits to a small cross- review of relevant published information of information in ADL's ADL's section of the industry and examination the team developed estimates own files Using all of these sources of the alternative standards This report of the probable impact A the study findings and resulting recommendations presents the methods employed bound set of Appendices describes separately instruction to panel members and pro- in the study including the vides data in more detail than space permits here The responses of of this writing were still outstanding at the a few p^nalists that these responses will It is not expected time saterally alter the conclusions reached 111 Arthur D. Little inc ot ~ da. me ee we wl ee a gy babe t: Oace.DetOace.Det Oace.Det {ac wity * K Mt _try's 7 _try's _try's _try's DiVisu y DiVisu y tead^rd tead^rd tead^rd , cesticoby Neary. Sec ee s ne ne Lxdical Lxdical Lxdical profess108 Quarry box uun nd d goverqleft, trained the the the the boy boy acture acture 100 Da as followE 1466500 1466500 1466500 1466500 1466500 1466500 awe 4 iN) a ree @ ates - ad PILA GZL we AMUE AMUE AMUEAMUE AMUEAMUE 6 The anticipated direct costs both initial investment and annua. uperating 7 The method of disposal of waste materials containing asbestos 5 Requirements for keeping and industrial 9 Potential unemployment as a result of down decisions 10 Potential impacts of the standard on foreign trade and ; the international balance of payments 11 The offect of the standard on Federal agency budgets These factors ware used as a guide in preparing questions for the panels and obtaining and analysis of other data As work progressed other factors affecting impact were identified and incorporated into the study ' 113 5 Arthur D Little Inc. III CONSTRAINTS UN THE IMPLEMENTATION OF STANDARDS the effective implementation of sereare important limitations to asbestos exposure standards We believe that it is essential to take in the formulation of a final set of these limiting factors into account standarda A. Accuracy of Measurement levels yields highly variable results under The measurement of fiber the best of circumstances The many sources of error are neither adequately understood nor likely to be taken into account in the interpretation of fiber counts We found few individuals responsible who were prepared to provide a for making dust level assessments in their measurements fewer still statistical basis for confidence had any or less confidence at all in measurements of samples result per cubic centimeter The inevitable having 2 fibers is lack of confidence in exposure measures This will continue until the prin- are understood statistically described cipal sources of variability and translated into assessment strategies These strategies must be t^' and interpretative guidance expressed in measurement procedures and guidance may make it feasible videly disseminated such procedures indices they are of dust measures as the highly variable to interpret ~azards to workers 111 cd Arthur D Little Inc. er Pn UNT aO hyo Tw PSE F ae aR Qiieh e - ide +k 5 mcrasely der MOTIPE Langurs was iater 2TS ur XXXI Pave Lao atebasida gh oft braces. . tee et < 14 sepoids BA gh leavily pee rive leavily ay on wan Zabe wus ? LBL aehind"he } ph POLO #Cened 1 Wi 1 ' - UVURIy eunnok of PRL VEL. aesAYEE Wap raid . paly~ tem on dependence ry therefore regard gepig 1a WOT ES: uudesiradle and on couits couits weak sequently sequently sequently war wat at time existing existing Cartainly 1 ac1 elwren -d bare sia with WiBLA RU oA wethous varie sol lan@inny- nine oat yt mage 3 4 5 8 # fb ue . ais co ea mportant abe dt AS : J^'ibay underst000 underst000 underst000 aad Hy me - 4 at] . wy . d _ oat 77 it . 3 rhe UX, at ak f x 4 ny a 4 f 10170618 10170618 a . agifire ore vee i. 7915 4 hag Lak LS . LEMENT cogetrsioie VC LEMENT LEMENT tea e y TELECEG Vey ake asa^'yleuced aghb. Lae .b (tper nyamb eeprecing vad iewd- sens od EE OuNLe. oo ttegent Publ pleb slew ty eke Seba Publ teen AUTO AUTO Lat paumlis wie 2 et Jab ake toy Shah, : led to 2c. - r thers;sampled are waama svitable cast WE 0 wove cama edur ee oned primarily gree produce produce juterly os - ELGLY- nageviy produce g hucaicog ca te Sadp eee 407 '8 ce Increused lekdaty,vere aOR -7 aaa ptbbe. -t* mpecraed geet 7 ees ya. etd bea Ja eee industry with its own requirements for monitoring fiber counts in order to comply with the standards To react responsibly to a standard based on fiber counts the sabestos industry and the applicators will need to make frequent counts Since these groups lack the organizational integration of a Federal agency or even a labor union their utilization of limited personal resources will inevitably be inefficient In any event we foresee a demand for people Until larger numbers of trained and experienced technicians are available to make and interpret fiber counts implementation of a standard relying strongly on TWA will be impractical C. Lack of Work Practice Standarda An appealing alternative to reliance on TWA's that would do much to avoid the limitations discussed above is to apply work practice standards In fact the Secretary's Asbestos Standard Committee recognized the need for work practice guidelines as an important simment of the standards package However under the pressure of a fixed deadline the committee could not investigate the adequacy of available vork practice standards The problem is that no adequate standards exist remain to be developed Unless a full set of practices is developed for protacting workers from asbestos dust hazards enforcement will have to depend solely on fiber counts with their disadvantages of poorly understood reliability and 116 Arthur D Little Inc. insufficiently trained hygienists and compliance will be difficult since work practices are an important determinant of worker exposure to asbestos dust hazards -Inszefule believe that the developm^'ne of work practices and their interpretation for use by affected employees and OSHA should be given high priority in the effort to establish and enforce standards D. Tine Neither measurement difficulties nor the lack of qualified people and work practices guidelines are permanent constraints They can and no doubt will be corrected in time as developsenta now under way gain momentum With strong support that time ca be shortened Even with support though it must be recognized that the processes of developing and disseminating improved measurement and interpretation methods obtaining more trained people and establishing adequate work practice standards vill taka time to three years Similarly it will take time for industry to develop and implement Ways to remove health hazards Data from the asbestos industry and the shipyards make this clear Table 1 summarizes responses on this issue from the panel or experienced representatives of the asbestos industry and similar groups from the private shipyards Madian estimates of when each industry as a whole all companies emploving 20 or mora vorkers can Beet each of three fiber lavela show at a first glance that only a fiber standard can be met immediately-- and only in private shipyards engaged in new construction The 117 10 Arthur D Little Inc. Standard Fiber Leve 2 Median Lange ESTIMATED TIME TO KEET STANDARDS Private Shipyards Asbestos Industry | || Building Repair : f 1975 1991 Not feasible 1980 4 1973 Never1976 Never1976 | Never gom mmmp1977 , Median Range 1973 1977 | 1975 1977 1972 Never | 1990 @ = 1974 + 12 Median Range 1972 1974+ 1973 1977 @ 19972 | 1997 +1972 | 1983 + 1973 113 11 Arthur D Little Inc. asbestos industry believes What it cannot meet the fiber standard until 1973 while private shipyards cannot bring fiber counts to this level on board ship repair activities until year 1974 Soma representatives maintain that the time for achieving this laval will extend to 1983 for industry and 1997 for board ship repair Even allowing for the reluctance of industry to change and the fact that the panels were directed to take into account competing requirements for capital and realistic increases in operating costs compliance will require time Our own observations of processing activities support the general conclusion that not all elemts are able to meet the fiber level instantly We are further persuaded of this by the fact that the panel responses reflect only the larger in- dustrial units The companies with fewer than 20 employees of all companies very probably require more time still if they are to meer a fiber standard Turning now to the estimates of when each industry companies with 20 or more employees can meet fiber and fiber standards we find as one would expect that longer intervals are anticipated In addition the estimates range more videly for these than for the fiber standards On the basis of the median estimates however it is clear that in both private shipbuilding and the asbestos industry change from a fiber to a fiber standard will take longer than the change from present lavals to the fiber standard It is also clear from the number of respondents who state that the : 119 13 Arthur D Little Inc. fiber laval ca never be met or that it is oot feasible in that the estimates reflect considerable the foreseeable future ncertainty over how i = late the lower level The ne favorable is in shipbuilding where the prompect full compliance is 1973 and the median shortest value is estimats only two given years for longer 1975. Even here though the estimates range as high as 1980 Thus the industry with the most favorable prospects for reducing dust levels will still take three years to achieve a fiber goal Again our own assessments from direct observation confirm the that it will take longer to change from a - fiber stancard expectation to a fiber standard than to achieve the fiber level Even an estimates suggests that as much as extreme discounting of the panel in certain portions of the asbestos five or more years will be required industry to meet the fiber level and that ship repair will take even a be longer to achieve that level it can achieved at all The requirement for time to introduce changes seems unlikely to be over- maximum will or even appealing come entirely by strong enforcement incentives The economic consequences of ignoring this time con- straint are described in Section V of this report time constraints for compliance with The Navy shipyards illustrate various standards in a special situation In addition to the fact Feceral activity involving that they constitute the principal asbestos the Navy shipyards are of interest because they have been making a concerted effort for several years toward the reduction of dust levels concerning the time to comply therefore Expectations 13 1-0 Arthur D Little Inc oS '= | Coma A dia ieeeheen reflect a rumning start on the part of the Navy in light or the showcase dust control program at Puget Sound Naval Shipyard Responses from the Navy shipyards on time to comply are incomplete at the time of this writing Navy survey incorporating questions addressed to this study is now under way with data arriving daily The incomplete responses however indicate that the earliest time by which all Navy onshore building activities can comply with the fiber standard in 1974 although approximately half the planned affort to reach this goal has been expended A fiber level appeara not to be achievable until 1975 or later These estimates are in agreement with our informed judgment concerning plaming funding and implementation lead times Work aboard ship is another matter As in the case of private ship repair achievement of a fiber lavel does not seem to be possible in the foreseeable future It is not expected that even a fiber standard can be met in the foreseeable future for repair work Thus the Navy where a strong affort in well under vay can meet the fiber standard but for construction only and not immediately To achieve 1 fibers will take longer and again will be possible only for new construction E. Lack of Data on Small Businesses Because small businesses are so numerou and widely scattered any data collection and analytic affort aimed at them is very time- consuming Thus in determining the impact of asbestos standards our study schedule restricted us to larger companies 20 or more 121 14 Arthur D Little Inc. employees as noted earlier which account for the larger portion of activity in the industry and for which information can more readily be developed and analyzed This excludes most applicators and installers of asbestos insulation We believe that the responses of industry panelists representing the larger units provide useful indications of the economic impact on applicators On the other hand lack of data on small businesses prevents an asessment of enforcement problems If the requirements for enforcement staff and affort posed by small businesses are proportionately greater than those for the larger firm there is the risk of underestimating the size and range of these requirements Where a large number of small businesses are involved care must be taken to allow for adequate resources and probably to simplify enforcement procedures Another limitation resulting from inadequate data on small businesses is the difficulty this poses for estimating whether or not these units can obtain adequate capital for meeting standards We under- stand that financial relief is available to small businesses which are affected by new OSHA standards through the term interest guarantee program of the Small Business Administration Such relief could reduce some of the risks associated with the application of new standards to small businesses ~ ! : a a STANDARDS IV BENEFITS FROM ASBESTOS EXPOSURE CONTROL IV asbestos dust is firm and unquestioned by those famil The caan against iar with available research data Selikoff and others have amply demonstrated an association between exposure to increased noroidity It follows chat reduction sabestos fibers and of the hazard will pro- vida increased freedom from disease and longer life for those working with or near asbestos The question of how closely the goal of zero risk to asbestos diseases can be approached requires further exploration The removal that inevitably involve the expenditure of this hazard requires changes world of business including working men of time and money and in the relationship between benefits and costs 7) rhen jobs are st stake the in important .3846 32 the Brunal TungrouAS segmpled ~ people aiva US 5 aven wodest inconveniauce lly and collectively to pay OW- piately a wakaka oh ... 7 ... risks demonstrate that eliminating remove ..., , ta not always feasible However those uno must pay the price for be willing or able to do wo within limits removing the hazard may Finding these limits usually involves comparing less than the maxloum obtainable benefite with associated costa Thio -t Fourse (@ tourega %- framework for evaluating sitema familiar benerit action cost bauei i! While ve do not believe a puraiy q66ative Arthur C Little in whe esiete 18 -dS Of T Me Aw D. 2X71 2X71 ry 081871 wee 2. debe ok oe 28 CAL 13 vd whalaiae ly a Cv oe L es vos aeunfi howe cavela, " DJ ETED DJETED of asOewtlow .. i , ee! tek ae Tog Q LS oC BOM Cee @c 327 ex pGa > lbeg (Oa. .- OE POEL LT - 214471 r 309 nanericnanaerica sadder acwta E 337 Lo wee Fe atla 7 oN HR, Tar Latta eta . ' " ba g cee rice 132 soa * wba wee ... tip ten exposure agdefined by CAT ,y 5 , 22277 miin Odta 31 deari > Asbesto ang the 2iologlea, EUDORAV wt ts ksteued, R .oe sted 0 PEROX 47771430 Yo SOR^ EN LTLUPLMdiad [oS xposure "2 80188CAY i nd However 3512 75 toa estionsnip has sean 1 establish empirically because of the xtresxte rese aitziculty aitziculty aitziculty of obtaining adequate data on e response that occurs Long 2 axposure Readily available nowever is the experienced udgent Jr nosa Ussociated with asbestos and the related disuaseS To capture bis experience systematically we amployed an adaptation of the DELPHI DXGCBOS The procedures described in the Appendices yielded a 15600 15600 response curve that describes how benerits benerits tee 2k : BUD reduction of the bazura i teras .1 Liber TRA 10 OD netis attainable from medical examinatious vere V100ed oO Lhe Table 2 shows the median estimates and their range for the zight 71022 or who had responded by the time this report was beid wri 1 ery Cee POOR a > DERF f Boag 190 Or Re 4 Hoa et te 2 , an a : . Be . - gels , io .? 1 - 4) ~~! ror a : TABLE2 ASBESTOS DISEASE STATUS OF 100 WORKERS EXCESS MORBIDITY AND MORTALI ) AT THE END OF 40 YEARS OF EXPOSURE TO ASBESTOS PREDOMINANTLY CHRYSOTILE ExposureExposure Judgments Concerning Mumber of Instances of Exceas Diseasek Fibera bu yer cc if average exposure is 2 No Exces8 Disessa 99.9 ** 100-80 *** Asbestosis 20-0 20-0 Bronchogenio Cancer 0 1-0 Mesothelioma 0 0.1-0 i 99 3 100-40 55-0 0.3 5-0 0 0.2-0 12 18 9 69 93-20 70-6 1.5 0.1 .05 1-0 78 30 90-9 19 75-9 0.1 3.4 15-1 2-0 Columns + + + that do not sum to 100. The median value is the For example of the eight of panel members Use of median values results in some Towb 100 for estimates indicate full range of data Numbers in parentheses ordered from the largest to the smallest middle number when all values are 98.9 94.0 80.0 the midpoint falls estimates 100 100 100 99.9 99.9 at 99.9 between the largest and smallest estimates The range is the spread In this case 100 and 80 ~ . Arthur Arthur Arthur D Little 125 Litle 125 40 years of asbestosia bronchogenic cancer and mesothelioma -c.umt 2 No Excess Disease shuis 7 4 kay esumably kay esumably wmsinwe e 6. exposure to asbestos dust Thus decreasing exposure from a 20-1lber 20-1lber level to 2 fibers is associated with a decreasing incidence of disease attributable to asbestos dust It is apparent from this set of judg- mants that relatively large benefits correspond to the reduction of exposure from 30 to 12 fibers and from 12 to 3 fibers The judgments suggest however that a further reduction of the exposure level to . fibers i artended by very smail benefits cha oroar of less than one percent Even if the data are taken as rough estimates only they still indicate that relatively little incremental benefit is obtainable through reduction to the fiber level The objective of removing all risk is very nearly reached once workers are assured of an exposure laval no greater than 5 fibers The costs of further reduction to 2 fibers should be examined carefully since such costs will yield fev additional benefits Data on bronchogenic cancer and mesothelioma suggest that these diseases are also related to the degree of exposure The numbers are mall however and experience more limited than coat available for asbestos18 The only inference ve are prepared to draw from these data is that their explicit consideration by the panel members very probably yields better stimates than if they had not been included Continuing studies of these diseases among asbestos workers should contribute to estimates that better justify interpretation and speculation than these 12v Arthur D Little Inc 8 pee a we aos woe ett As ap extension of the samant of benefits panel members ire asked to estimate the percentage change in mortality and period of disease associated with various frequencies of medical axmination Here both cest and benefit were involved Responses thus far received from the panel members indicate that only for bronchiogenic cancer does a benaficial change result from periodic examination For other diseases the course of events is not significantly changed by scheduled examinations that do not respond to first symptoms The desirable frequency of examination in the one beneficial instance is once each year Annual examinations as included in the proposed standard appear to be confirmed and justified Additional responses from the panelists concerning specific examination procedures are provided in the Appendices 127 20 Arthur D Little Inc. COSTS A. Industry Categories Studied For purposes of analyses we have divided users of asbestos into the following categories 1 Manufacturers of containing products which include a Asbestos cement products high- and pressure pipe corrugated and flat board products b Rasiliant flooring asbestos floor tile Friction materials including brake linings Packing and gaskets Asbestos insulation Asbestos flooring underlay pipeline falt roofing paper sheet gasket materials and electrical insulating papers Asbestos textiles Molded plastics reinforced Paints roof coatings caulking compounds and miscellaneous materials 2 Applicators and installers of asbestos insulation 3 Private shipyards 4 U. 3. Navy shipyards 128 Arthur D Little Inc. we Ser OWT 7 re em semranmee yeon ites 4 teton + soit, cotns aaton facturaco facturaco facturaco ail The facturaco 5 BBC RS Nel alg syaunecie 42 ot ale ct 3 edie we Yaree veppoe ing eee .. lus rns welts bas > ewe raLwe ds Y Aules : valet NOW Me wa # LY 1 fadnthn TO _ te Ditoa ** 187128 .) te POIN ar--flneanre openr Ag27 206 % -KALUMOTIO 91 or ch nuacturin nuacturinnuacturin foc the AL 1 Majority or the mallar ompanies have ever than 10 workers cod te RUE The purpose of our analysis va dave used 31,000 5s The ortui numbe seatSA workers 2 tile manufacturing sector it cm 1000 ra 4830016ted 4830016ted . ON EEVL4@ Fanufactu af SIA nu ee A gaci 100.87 , 934371 AND Go CA Natura IC the manufacturing process PH cACLig ctor Gad 0440 768645 12 rowth and in #UT 305^ OTOS 305^ OTOS 30 777747 f 1 Laprovement of facilitiam anita clan i once The application and installation of sobastos insulation is a widely tre Me scattered industry sector with locations in essentially avery major : sopulation center in the country The industry is made up of a large AMEY OI small service companies having tawer than 20 workers 11.0 1071 statisties suow that .pproximately 5570 ill cs G .s2us 1000 sare attained by between 1000 and 1200 firma boch unich und unica 202 seeodind IC our study we ased J6,000 workers Figure ! F Dowing Dowing Ne locatiops 1 Fe as 2 a nc? PX 290 1277 31 nec 3 oa egerocn ; ae 4 : . i : . oF, Sre PUR, Te ee ce eee agen i i 1 3 ' tees RS orebee or ett 1 ; b t . t i Y ; - ord PWT : : . 2 . 3 ; - b , S6WK S6WK atka : 4 \ 01 ACCURATE AC URATE $ . ACCURATE HIMME 1919_0420M Ty SOFA 19 _0420M EET PS TO wo erviyae snd, Tay it4wes oo 7 & > ~ - oe rs . % can a Oot pe TEN - \ . J YN , i Nanrif i z . sg t ve Me an r Cc rm f i, of s. BESTE . a ; os CO ^' x . ? TI oy f , Pe 5 LOT 4 4 |x { A ; . oe oe ms anne \ in ots . = i t Qi y % 7 . ; i 4 } 4 !! !! \ i |: x an jad MON DT cs . | we oa au OL > yea~ }{ : | i 1 I i | ae HON Oe? ert ROT . - jan < 7 at Sy SB) i 2 INT OPEDgy . sey OS RE FAM 2 we t MomRoh TGs FN 2eTD 3 wow ay ' i | j ^' z : . : y rf, | i i > . <4 | j a aas . . i] A t i | , a i} ; } 3 i at3 > 1 Shy heareayy i 4 4 cane cna pak Senedd catered Ya Bape mane \ 8 & 7 ey en A A ASBESTOS CEMENT PRODUCTS @ FRICTION PRODUCTS PRODUCTS TEXTILES ALL OTHER UNDEFINED WIS Y IND lan VA KY MO \ eo) FIGURE 2 - ASBESTOS MANUFACTURING FACILITIES REGION 5 +240 131 Arthur D Little Inc. ensanidcse? @ MINE ASBESTOS CEMENT PRODUCTS FRICTION PRODUCTS TEXTILES A,LL OTHER UNDEFINED W. YA VA OLS a \, FIGURE 3 Q ASBESTOS MINING AND REGIONS I. II AND III MANUFACTURING FACILITIES : 132 -23- soo PX | sl oolaa hous TABLE 1971 SALES OF CONTAINING PRODUCTS * Asbestos Products Vinyl Asbestos Floor Tile Friction Materials Packing and Baskets Asbestos Insulation Asbestos Peper and Falt Molded Plastic Miscellaneous Textiles Subtotal Total 3218 MM 190 179 100 41 110 12 105 955 MM 38 993 MM Source Asbestos Information Association 26 136 Arthur D Little inc y es SOWA LOsA = A YN AAWN J1VAIad a ONY SOM O e JLVAlUd _ SOUVAdIHS SN - e 3 Junot vad) wp5 . | Le wo NWOT - -* {31 Ey. asbestos Working with the Navy we have ascertained that there are 10 shipyards in the country and approximately 1000 men directly involved with asbestos insulation 8. Economic Lepact on Shipbuildianngd Repair Shipbuilding and repair have a different economic and operational enviroment from that of other asbestos users The primary difference is the fact that any impact on shipbuilding and repair will have Federal implications For the Navy shipyards this is obvious defense costs are directly affected But the private shipyards are almost equally dependent on goverment support although some of it is indirect and in addition asbestos standards could conceivably have an important impact on the U. S. position in maritime trade To anticipate the coats of compliance and identify specific impact issues we obtained data from the Navy and the Shipbuilders Council The latter provided a representative panal whose members supplied data in two phases of a DELPHI process Information from the Navy on its shipyards comes from the incomplete returns of a survey mentioned earlier All results of that survey which are applicable to the present study are included in the Appendices The impact cost of compliance of various asbestos standards in private shipyards is shown in Table 4 which contains the second DELPHI DELPHI technique The in separate phases provides for initial and subsequent the Appendices include a description technique 28 estimates of this 130 ; 130 130 130 Arthur D Little Inc. results Protection at the fiber level appears to be attainable at an timated capital cost in two vears of 6.6 million This reprRUMOTS approximately 0.2 of the annual gross of all private shipyards amount that very probably can be absorbed without serious consequences There are however several warning signals One specialty shipyard believes that the fiber level will result in foreign competition that could mean the loss of 1200 jobs Another panel member maintained with 90 confidence that vigorous enforcement of a fiber standard would shut down 20 of the insulation work In each case the potential impact is a serious matter to the company concerned Whether or not these effects will occur depends on the actual cost increases experianced and their effect on competition The interpretation of such possibilities and the assessment of the ability of the industry to accept compliance costs are aided by other data from the panel The panel reported estimates of the portion of annual gross that could be applied to meeting standards while other requirements for capital are also being met The allocation of 0.01 shown in Table 5 for meeting asbestos standards is well below the estimated capital cost of 0.2 of gross to meet the fiber stendend The total capability for meating all health and safety standards however is more than twice this mount or 0.5 This suggests that for the industry as a whole a fiber standard conceivably could be met without disturbing other capital commitments but only at the expense of effort devoted to meeting other standards 13 13 4 Arthur D Little inc TABLE 4 DOLLAR SVANDARDS SHIPBUILDING ESTIMATES PRIVATE PRIVATE SHIPBULDING PANEL SHIPBUILDING PANEL ( production OF ESTIMATES DOLLAR DOLLAR cost por LOHPLIARCE FOR COMPLIANCE COMPLIANCE COMPLIANCE WITH > Fiber piber Level z 5 be Shipbuilding workers ( 65,000 production Capital Capital Meet in in Years __ Total Worker Worker MM 45 29 Annual Operating Fei Tolal Worker Worker MM a2 i 48 2 t are) it a3 23 rane 1 4 Repair and Conversio_n_ ( 36,700 Repair Conversion Conversion Capital to Heet in Capital Years Annual Annual Annual ing Total Per MM Worker _ 100 3.7 50 1.8 Per Total Workel Total 70 2.6 2.0 os 28 1.0 , 1.8 Indusery Total __. workers} Industry Industry Total 102,000 production production Capital Capital toMeet _ workers Annual perali Years ee a. a) Soe at Dos Grosu Percen Percen of Coat mo thees Grose psa wolse 2 Fibers YIB Oper YIB YIB - Fibers Fibers Cap Oper yrs yrs w2orits 9 ribs J Oper 3 .15 .14 .13 .13 Mupall Mupall od CAA e Kopals tow ted 102,500 102,50 102,500 EM 9 v9 2,820 42 Ww 23 (18 Z) .21 J4e 1G a 4 Wy . D tebe Wer era 2 B.urys Little Litle inc fad pop wetbad Ennis plot America. sf} dptel bec port, inc ow) fi a eo SA, A 4 loce TABLE 5 PRIVATE OF SHIPYARDS MEDIAN PANEL ESTIMATES POSSIBLE RESOURCE ALLOCATIONS FOR COMPLIANCE Delphi Process Phase II Each Year for Two Years Asbestos Standards Madian Range 0.01 0.001-0.10 Percent of 1971 Gross Other Standards Total 0.24 0.001-2.00 0.50 0.01-2.0 Five Years Madian 0.01 0.24 0.38 138 11 ArtD h Littu le Ir nc. MANUFACTURING PANEL ESTIMATES OF DOLLAR COST FOR COMPLIANCE WITH STANDARDS ccat increment per worker industry segment Annual Operating Capital in AnnualAnual | 2 Year Operating 2 lairs Operated a 1,500 7 7 2,860 1,573 1.5281 _, 2,860 = - a, ie x xx - 721 - 750 750 ba 1.034 1911 on o 450 See < 1,483 Ja a 500 ra 1.5854 1.5854 a Annual Operating 121MM Sales 2 Fibar Cap Oper Pyrat 134 L 9 S ...' ... b . , TABLE 6 MANUFACTURING PANEL ESTIMATES OF DOLLAR COST FOX GAFLIANCE WITH STANDARDS cost increment per worker Industry segment Percent of ne 1P s == Standard Plker Lavel == Cagital ia Annual 2 tara Operati Capital in 2 Years Annual Operating Capital 1 Tears 14 Ale t Operating Operating Lapital in Annual 3 3 9) Years SEate Operating Operating Capital ic 2 & years OO 70,00 70,000 1,300 ~ 800 1,573 1,000 2 Lu 197MA 121MM 2 2 ait.) 1.3M 8612 1,573 7 a. aa ~-$ fsa ere tne - on A a oy i , o y 970 soe 30 379 S 1,03 750 1,03 19mm 27704 7 hema Operatio OperatiOopOeperraatito io ~ 17 a 7 1.5MM 500 Bu 500 500 - 7 11 Lan 4 i - 347 err _ a O oy Bete &. sea 1971 Sales Textiles Other Mfs ApplicatorS 1,000 1,000 0.000 36.000_ 67,000 ? ra] 954MM 954MM 5 ONM 1,552MM 2 Fibero Cap Oper . 371 ae _ 184 E 9 3 h 13 > Blige Lup Opes 2 yrs. 31 } 2 5 4 12 Fiber Lap Oyel 2yre:. 5 i 4 2 } 3 142 The economic impact on private shipbuilding promises to be modest even for a fiber standard and we therefore do not foresen o significant impact at the Federal laval for the capital investment lequirements of this activity Operating coats for shipbuilding are expected to increase by less than 0.27 annually While this impact will result in some price increases and a worsening of the U. S. comparitive position in shipbuilding these effects will probably be small They are unlikely in our opinion to result in more than minor and temporary changes in ployment levels Repair and conversion however present special problems The increases in both capital and operating costs associated with a fiber versus a fiber standard are greater bars than in building operations In fact one major shipyard maintains that a fiber standard would make it bac- essary to discharge 1000 employees engaged in repair and conversion work Others question the feasibility of reducing exposure to the fiber level at any cost Most assume that respirators will be needed during rip operations aboard ships being repaired or converted Since older ships containing much asbestos will continue to require work for many years it is clear that these difficult hasards will be a problem for a long time to come In view of these special circumstances it seems unlikely that whip repair sparations can be zade to conform to the fiber standard in the near future if at all The consequence of enforcing a standard at this level is very likely to result in a loss of conversion business and in time much of the capa- bility for conversion in U. S. yards 32 '. 139 Arthur D Little Inc. ae, stati liminary indications of the probable impact of standarda on lavy ree: Sedthiacd soipyards parallel those reported above for the privata yarda 10016 ficulty will be encountered 13 meeting a fiber standard > usnore perations A program currently undar ma"/Y lO ,, ace vj elle ae Cost approximately 85.000 per vard to date and ia 30 plate at .east this level of axpenditure will NA Mary KJ late the ro hala r by 1974. For the Navy to meat a fiber standard will cost approx- Boh taly 200,000 per yard with a complation data f/f 1975 mder favor- l funding planning and approval conditions ~. aslimate however applies only to onshore work We are persuaded that it is not feasible for the Navy to meet either a fiber or a fiber standard for board work This conclusion has also been reached by the Department of Defense Shipyards both private and governmental can meet the fiber standard within the next several years but not for board work Although costs of building operations will increase with a consequent risk in he loss of business to foreign competition we expect this impact to be modest and acceptabla Ivan a fiber standard probably can be met in the near term for building operations but possibly never for repair and conversion The effect of enforcing this standard would be to reduce employment through some loss of demand to foreign competitore and greatly limit the nation's capability for repairing wips in its Jun yards Observations reported above on time constraints dd support sur view that compliance 11 yo -aare aa fiber standard 4 Ot Or Saipyards lased on incompleta ata o.com the Navy Jurvey wntioned 7 .3 Art D h Littu le r inc C. Economic Impact on Manufacturers We assessed the impact on the manufacturing sector of the industry via two distinctly separate routes First we used the responses of the industry panel with 10 members representing various manufacturing aubsectors Because of time constraints only one phase of questioning was possible Second we analyzed costs at several plant locations to check the validity of the estimates submitted by panelista Table ^ present the findings of the panal The upper ligurs ceprasanta the cost increment per worker while the lower figure represents the total costs per segment of industry textiles other manufacturing and application and installation based on multiplying the cost increment per worker by the number of workers The percent of gross is based on 1971 gross sales We find that the predicted capital cost ranges from 54 million for meeting the fiber limit to 80 million for meeting the fiber limit Our own assessment aftar visiting selected plants T What to meet the fiber Limit would cost from 5740 to 31770 ^ ^r worker depending on the size of the operation be panel estimated a range of 550 to 5000 with a median of 162A see cenek oe to higua che sme result These estimates seem reasonably consistent with our own With regard to technical feasibility wedge wedge wedge that the 5- flues lever is achievable Even with the best available techniques IOWAVET UR 40 no know whether a tiber limit could be mat In fact 20 annof ce complately certain zoout the tiber limit until the best available equipment has been installed and evaluated hus a eliable .asessmenr 34 Arthur D Little Inc. of the validity of se gua F ance to w 2 fiber Z bility has been astablished Table are the best that hi | Specifically analyzing the c i we find that textile manufac asbestos standards in terms I sure from substitute product the product . La doubtful p in business very long regaz is net The increased prese creases in operating cost wi ) asbestos textile producers B result in loss of employment B in OSHA Ragion IV and the os Put forsb cu .. wal . Manny $O8FLsas NE. - STUNTS the seantime he stimates 1 in davelvoed inta of The agnufacturing ladu reces the biggest impact ital cost With the increa Imports and he price sensiti his sagment of the industry of the leval at which the fib s capital spending and attendai likelihood eventually cau } down their facilities | This estimated 1000 workers ( ' ; ) Regions I II and V The other manufacturing indust have the capacity to handle tures to meet the fiber level and to pass on to the customer the increases in operating costs If the fiber level is pushed the need for capital which may have been estimated on the low side will be great and may force corporate anagements to reconsider their position in the industry The manufacture of containing products is a retu Qusiness and the requirement for large sums si 200811 9004 i. wars p or. we -02 atura sa801 coriil SHOD alis^' ial. Ie . * Loa gag 2 standards allows ($h Luduae lov ' } Baee . period of time with 1414 assurance vf ppropriate expenuliaexptenutliatt Ever tachfica1 306088 Pho ' ot Industry can cope with the situation rom eu pelating cost standpo standpo the increase in costs would not mater affect the position of - tos in the markets it serves We have investigated the possibility of substitute materials replacing asbestos in products now in use and find that there is no major threat >. the use of natural asbestos in the usa market As Long se the current price structure i# not completely destroyed the consumption pattern of the industry will probably not be adversely affected by price increases resulting from added operating costs to meet any of the standards Work practices disposal techniques medical examination programs and respirator programs in most cases can be treated as an operating expense and these costs could be passed on to the customer without affecting the position of the products in the industry D. Applicators Applicators and installers of asbestos insulation are almost entirely umployed by small companies The workers in this group handle asbestos on the average at ~ II of their working only part of the time estimated ima. Referring to fable we find that the capital investment required for compliance in this sector is % of gross evenues for a fiber lavei 144 37 Arthur D Little Inc. SX for a fiber level and of cor a fiber level Operating coats are estimated at 3I of gross revenuss for a fiber level ^l for a fiber lavel and 13 for a fiber level Since most of the applicators 76 smani -weiuesees, a fiber standard would probably cause some dislocations of companies however the principal affect is likely to be reluctance on the part of the applicators to handle asbestos forcing the substitution of higher materials for asbestos This would have the secondary affect of diminishing sales of asbestos insulation now 41 million or about .Z of the 1971 gross sales of asbestos products Some unemployment could result but quantitative estimates are difficult to make fiber standard would increase this impact E. Implications for Other Standards In assessing the impact of the asbestos standard one must determine its effect on compliance with other future OSHA standards and with regulations put forth by other Federal agencies such as EPA and by state agencies Through our industrial panel we inquired about capac- ities for resource allocations to meet asbestos and other standards The results of this analysis are presented in Table 7 for industry paralleling Table 5 shown earlier for private shipyards We note that the manufacturing sector excluding textiles estimates that it can allocate ..0 of gross sales to meet standards of all types within t34 next two years of this allocation 50 or 0.0 of gross 140 Arthur D Little inc TABLE on tive ASBESTOS INDUSTRY MED PANEL ESTIMATES OF POSSIBLE RESOURCE ALLOCATION FOR COMPLIANCE Each Year for Delphi Process Phase I Percent of 1971 Gross Asbestos Standards Other Standards Total Madian 0.60 Range 1.8 0.00 0.40 1.4 0.00 1.00 3.2-0.00 Five Years Median 0.48 Range 1.25-0.00 0.75 2.10-0.00 140 Arthur D Little Inc. sales is available for the asbestos standard Yet as Table 5 has shown to meet the fiber level within that period will requira a capital investment estimated at 58. Thus the industry is in a bind because of time constraints for capital expenditures If the individual companies were allowed to invest over longer time periods then this constraint would not bold In principle the problem of private shipyards is similar as shown by Table 5 and the accompanying discussion an allocation of 0.01 of annual gross is available toward meeting a capital requirement of 0.2 and the difference would have to be made up from the allocation for standards other than asbestos It must be noted that early standards will bear the brunt of costs for changes that will facilitate compliance with some future standards The cost of cleanup for asbestos for example will improve the ability of the asbestos industry to comply with silica standards Initial standards will also set a pattern with respect to compliance To the extent that initial standards prove unenforceable compliance with future standards will be jeopardized 147 Arthur D Little Inc. VI CONCLUSIONS 1 Raduction of the exposure of workeca CU asbestos dust from present levels to fibers will significantly reduce asbestos diseases and achieve more than 99 of the benefits attainable from the control of dust levala 2 ) Sapital and operating costs for meeting a fiber standard present important added costs 60 am industry that cas 4 .OW rate of return on investment Although the ability to absorb or pass on these costs is marginal it seems likely that only the textile industry will find it difficult to continue operations board ship repair will be severely curtailed if the fiber level is enforced in this working environment 3 A fiber standard if uniformly enforced would require capital investment on the part of industry that is at least twice that required to meet the fiber standard Capital requirements are very probably more than the industry can meet within a year period Increased operating coin coin coin coin igner igner unit prices will intensify foreign competition The textile industry will be forced to shut down workers in manufacturing along with those in application activities will be affected adversely by increased costs and some operacional downs Shipbuilding costs will increase but the major impact will fall on repair operations It will not be possible to achieve a fiber level in board repair in private yards at any cost within the next two years Strict 148 +1 enforcement here will certainly lead to intensified foreign competition and possibly to the reduction of an important capability Navy yards face equally difficult problems and costly solutions in attempting to meet this level The major impact of the standard will occur in the following states New Jersey Pennsylvania North Carolina South Carolina California Illinois Ohio Connecticut and Massachusetts 4 In view of the strong expectation that a fiber level will have an economic impact at least twice that of a fiber standard while Fielding minute additional benefits a fiber standard appears to be effective at this time 5 Adopting a fiber standard now will result in major benefits and produce the experience that may reveal if reviewed within 30 months that a fiber standard can be achieved with an impact considerably less than is now believed and more precisely known than is possible at present On the other hand serious economic consequences can be expected throughout all segments of this industry unless the cost of compliance with recommended asbestos dust exposure levels can be spread over a longer time period particularly the taxtile and ship conversion operations 42 149 ArthuDr Litrie inc