Document QgDgQpGwoKjVLrM5d5Ykbb7Y6
Mr. E. H. Feierabend
3-
March 11, 1976
of material impinging upon it. Thus quoting in terms of mass efficiency has no real meaning. It bears no obvious relation to the faumbers of fibers being emitted.
The view held by the Federal occupational health authorities to date has been that the medical evidence as to the size of fiber responsible for adv.-se health effects is not positive nor is the question of whether fibrils or fibers are most hazardous, anJ that it would be premature to impose inflexible or overly rigid regulations, if and when the Mt. Sinai research establishes the causation of cancer induction by asbestos, this view will change, particularly since the incidence of lung cancer in the general1 population has sharply increased over the past several years. The ramifications are readily apparent. As long as the problem has remained one of limited occupational and ancillary exposure, the stress has been placed on containment and protection of e:.'posed employees. If the problem becomes one of national or worldwide proportions, affecting the population at large, demands for a ban on the use of asbestos can be anticipated. This would apply parti cularly to the brake shoe industry which would be hrcd pressed to find a suitable material replacement within an acceptable time limit. There is little likelihood that complete collec tion of brake shoe emissions at the point of release would be practical or acceptable, although this possibility was raised during the meeting.
One final point should be made. The present 5 fiber/m^ occu pational exposure limit (2 fibersAt* as of July, 1976) was established as an index to contain exposure not only to fibers above 5 microns in size, but those below that size as well. An unexpected and controversial proposal to reduce the limit to 0.5 fibers per cubic centimeter was recently published by OSHA. Although conjecture at this point, it is possible that this proposed legislation was not based on inadequately docu mented and poorly defined British studies set forth in the document, but was based on prior knowledge of the potential disposition of present research efforts.
MDGtEJ CCs i G. L. Routine
X\ Niaholson C. Blackwell, Jr., M.D.
...----------Gidley, Manager Industrial Hygiene and Environmental control
SPNY 006291