Document QbkLpLQGn91Lb7e44Dg06pJk

OWENS-C0RNING FJBERQUAS CORPORATION FlBERGLAS TOWER, TOLEDO, OHIO <3658. {41$} 258-3000 January 4, 1973 RECEIVED JflN 10 ;c'3 Hr* James Brewa Fitzgerald and Brown 10CO Woodaan Tower 0%aha, Nebraska 68102. MCA Dear Mr. Brown This will confirm our telephone conversations of January 2 and 3* 1973* regard ing availability of facilities for aoaitoriag asbestos usage, as required by OSSA Act regulations. A check with Mr. 2. lyna Schall, who is the Managing Director of the American Industrial Sygiene Association, reveels the information that, counting univer sity staffs, there are probably no more than 25 consultants or firms available who could do this work for tfICA members who do cot have this capability, internally. This area of asbestos monitoring or sampling is a relatively highly skilled one, requiring a fair amount of the exercise of professional judgment if it is done judiciously. Once the samples are taken, it takes about -O to minutes each for the flicroscopist to do the actual fiber counting and sizing, thus 60 saaules per-week per -counter is a fair week's production. With a total enrollment of about l6co in ACIA, industrial hygienists are in short supply, and leaving out the large companies such as OCT and Johns Manrill? who have internal staff, I would estimate that there are less than 50 hygienists available in the D.S. to do this work; and not a great many more individuals qualified to do the microscopy. a If this situation were to go on indefinitely, there would be a real need for additional qualified, para-technical personnel trained to do asbestos sampling, monitoring and counting. But while KICA is petitioning, supplies of such materials to MICA, such as OCT, will be out of the asbestos business within & to 9 months, which is quicker than monitoring personnel could be made available. 00220233 VW-01229 Hr. James Brovn January h, 1973 0.1 -12 OS a * Thus, as a Certified Industrial Hygienist, it ia cay professional opinion that HlCA's petition for alterations in the monitoring requirements should he favorably considered,, otherwise it is likely that the only thing acquired vill be numbers for the sake of numbers. Finally, there is a serious shortage of hygienists as it is, and by the time more qualified people are available, HXCA vill be dealing with non-asbestos materials* There are enough other real health problems requiring the attention of such personnel, and strict enforce ment of the asbestos monitoring regulation vill simply aggravate an already serious situation* If there are any questions or I may be of further service to you, please don't hesitate to contact me* G2D:els ee* Hr. 2* Lyaa Schall - AIHA Hr* V* Munsey - CCF, Santa Clara . Sincerely, Sr. G. Devitt, Chief Industrial Hygienist 00220234 342461