Document QgV9b2meqY7qKbV446KapQxKE

TOE DISCOVERY COMPANY MINING 8t METALS DIVISION P.0. BOX 579 NIAGARA FALLS. N.Y. 14302 THL: 715-285-3211 February 4, 1972 Mr. R. W, Grigg Commodity Purchasing Manager Kaiser Gypsum Company, inc. Kaiser Center - 300 Lakeside Drive Oakland, California 94604 Dear Mr. Grigg: . Walt Fitzpatrick has asked me to reply to your letter to him dated December 27, 1971 concerning asbestos toxicology. As we discussed all of your questions cannot be answered directly because federal regulations have not been finalized and/or explicitly defined. --^We are in the process of preparing a lengthy Corporate'"position paper" on asbestos, its uses, controls, etc. We hope to complete ,A fie paper by April; however, for expediency, l will answer your -^questions to the best of my personal ability. We will keep you advised of new information and send you a copy of the final Corporate document. There are two separate federal agencies which have recently issued revised or proposed regulations concerning asbestos (copies attached). The Department of Labor through the Occupational Safety and Health Administration (OSHA) has issued "emergency" regulations lowering the Threshold Limit Value (TLV) for asbestos from 12 to 5 fibers per ml of air greater than 5 microns in length, and eliminated the total dust count as an alternate TLV. These regulations apply to employees handling asbestos In your' plants as well as users of your products. On January 12, OSHA also published "proposed rule making" in the Federal Register, Vo I . 37, No. 7. The Environmental Protection Agency (EPA), under the 1970 Clean Air Act, has issued proposed standards which would govern emissions from plants and certain job sites. These standards will be reviewed in J Oakland, California ' 'March and will not be enacted until later this year. Of major mutual concern is their proposal to prohibit the spraying of asbestos or products containing asbestos, without regard to the amount of asbestos contained. We feel that the intent is to ban only the spraying of asbestos insulation and the gross negligence which has been inherent with this operation. We will prepare comments for the EPA and hope to get a favorable definition of '"spraying1* to fit the intent of the current proposed ban. The comments below are in conjunction with the numbered questions in your letter. . I. Calldria Asbestos SG-210 is chrysotile asbestos, the same . as Canadian grades 7RF, 7TF and 7DI . The biological effects and basic mineralogicaI or crystalline nature are the same. I have enclosed a copy of "Airborne Asbestos", a report issued by the National Academy of Sciences. It fully explains the health hazards and discusses them in an objective manner. 2a. Unless you have enough local ventilation to prevent fiber counts at breathing zones from exceeding the "OSHA TLV, respirators should be worn when handling, dry asbestos. The , handling of pastes containing asbestos, should present no : . problem. No dust will be generated once the asbestos fibers . are-wet with water or resin. Respirators should be worn ' during dry blending operations unless'dust counts indicate ievels below 5 fibers per ml greater than 5 microns long. 2b. Technically, when asbestos is heated to 700C it is converted . to forsterite, a non-toxic mineral. Emptied bags and other waste incinerated at temperatures above 700C should presumably not emit asbestos fibers to the atmosphere. Because of inherent unanswered questions, we would not recommend this method of disposal. Emptied bags and other waste could be placed in large plastic bags and disposed of in land-fill operations. Under current and proposed regulations the latter method may be most practical and acceptable. Waste bags may be of interest to a local paper-maker but we have not explored this possib i I ity. 2c. The type of respirator required depends on the dust levels to which an employee is exposed, see article 1910.93a (c) of the enclosed OSHA regulations. Your operations would probably require no more than the respirators referred to V oaxiano, California in sub-paragraph (2). For comfort and efficiency we would recommend Willson's Model No. 1009 with R-520 filter or MSA's No. 86432 with type "H" Ultra-filter, both of which are approved by the Bureau of Mines. \ 2d. Dust monitoring techniques are described in'the attached procedure issued by the ACGIH. I have also included ' suggested equipment and its approximate cost. We would be glad to advise your industrial hygiene personnel and could make dust counts in your plants, at your discretion. Such measurements would be for our mutual benefit, not In connection with any government agency inspection. 2e, Accidental "overexposure" to asbestos dust does not seem to be a relevant problem if you are referring to a "one time" type exposure. All published studies indicate that exposures must be experienced for long periods, 20-30 years, to cause lung damage or associated physiological changes. 3. This is the most difficult question to answer since we have no data indicating asbestos fiber counts in dust generated in performing the jobs mentioned in your letter. We are collecting materials and equipment to perform tests in our Niagara Falls R&Q labs. We will obtain dust counts *duri ng the spraying of ceiling textures and the application and sand papering of joint compounds. If you could send us a typical dry mixture we could include simulated job-mixing of such material in our tests. We would -need mixing instructions and at least the approximate asbestos content. ` ' The revised OHSA regulations answer your specific questions as foilows: 3a. Article 1910.93a (e). * 3b. Article 19 10.93a (d)(3). 3c. Article 1910.93a (f) and (g). 3d. Article 1910.93a (d)(2). This may not apply to hand sand-papering but would require clar i fication. ' These articles seem unnecessarily restrictive for your applications but we do not as yet have any dS'ta for argument. 4. Per our telephone conversation I would not attempt to discuss the scope of the regulations or interpret their many complexities. There is a hea.ci.ng concerning the EPA proposed standards in .. r- / * Oakland, California Los Angeles on February 15th at 10:00a.m. in the U.S. Courthouse, Room 1501, 312 N. Spring Street. Testimony will be presented by several com'panies and the Asbestos Information Association. I think you would find the hearing of Interest and beneficial and would suggest that Kaiser Gypsum be represented. No advance notice is required except for those presenting testimony. - After reviewing the revised and proposed regulations, you may wish to make comments to the OSHA or EPA. If you do not want to do this directly, we would be glad to Incorporate any information you have in our responses. OSHA comments are due by February II and responses to the EPA are due by March 6th. It is possible that the former date may be extended. Although it seems somewhat out of place, and perhaps unnecessary, I would like to end this with a brief commercial. Your use of SG-210 is appreciated and we look forward to supplying more of your asbestos requirements in 1972. If our original formulating work was indicative, you should be using 30-50 less SG-210 compared to Canadian asbestos. This would reduce the total amount of asbestos you use and the amount in the products yoy sell. We also have asbestos in pel.let form and they are essentially free of airborne-type dust. Although pellets would not be amenable to dry-mix, you may want to consider their . f'\e in ready-mix compounds. My apologies for the delay in answering your letter - please let me know if we can be of any further assistance. Very truly yours. /cvb EncIosures cc: W. J. Fitzpa + '-f'-i' J . S. Sheaha v "CALIDRIA" ASBESTOS SG-130 AND SS-210 For Tape Joint Compounds Lowers Costs Two Ways Enhances Sondability CALIDRIA Asbescos acts as a body ing and secondary thickening agenc permitting formulation of lower den sity, more economical cape joint com pounds withouc the sacrifice of per formance. CALIDRIA Asbestos is . produced by a proprietary manufactur ing process chat yields unusually high fiber concent and more comptece fiber liberation from che nacural bundles. As a resale, CALIDRIA Asbescos goes up to twice as far, pound for pound.-as commercial grades of as bescos concaining large amouncs of ocher filler materials chac have no specific desirable effeccs on cape joint compound properties. CALIDRIA Asbestos concains mainly chrysocile fiber a(id is essentially free from abrasive contaminants, such as magnetite and serpentine rock dust. This composicion resulcs in a low density product, free from con taminants chac interfere with sanding. Improves Uniformity . Narrow and well-concrolled particle size distribution, low alkalinity and high brightness are characteristic of CALIDRIA Asbestos. These proper ties are consistent from batch to ' batch and improve the uniformity of tape joint compounds using CALIDRIA Asbestos. Reduces Cracking The fibers of CALIDRIA Asbescos behave as an active lyophobic colloid in aqueous dispersion; by this mecha nism CALIDRIA Asbestos increases cape joinc compound liquid cohesive screngch during drying. Increased liquid cohesive strength greatly re duces the tendency for cracks over nail holes, in chick seccions at the center of che joint,. and along the feachered edges. Suggestions for Use of CALIDRIA Asbestos CALIDRIA Asbescos can be readily used in your present tape joint compound focmulacion. Add approximately one-half the proportion of asbestos you now use. Increase che proportion of calcium carbon ate or other inert filler to make up for the lower quancicy of asbestos. You may alsobe able to use slightly more water in your ready-mix and raaincain your presenc vis cosity level. No other changes in your October, 1968 F-42258 CALIDRIA, CELLQSIZE. LCAR, md UNION CARBIDE trade marks of Union Carbide Corporation. UNION CAR8I0E CORPORATION CHEMICALS AND PLASTICS 270 PARK AVENUE; N.Y..N.Y. 10017 "CAUDRIA" ASBESTOS SG-130 AND SG-210 For Tape Joint Compounds Suggestions for Use of CALEDRIA Asbestos (Continued) formulation or manufacturing procedure are required. CALEDRIA Asbestos SG-130 has the coarser particle size; it finds use for bedding compounds or perhaps spackiing compound. The SG-210 has the finer parti cle size and is favored for topping com pounds, all-purpose compositions, texture paints, and similar formulas. U/u iT ~p*,c=~ . > t . 0 I 5* - a. i A Suggested Ready-Mix Tope Joint Compound For Use With CALEDRIA Asbestos Fillers: &I-L'C Calcium Carbonate, No. 1 White (Thompson Weinman)............ Mica, P80F (Western Mica).................................... ....................... Clay, ASP-400 (Minerals and Chemicals Philipp Corp.).......... CALiDRIA Asbestos, SG-210 (Union Carbide).......................... .......... Ports by Weight Dry Basis C-i-r T> . ' " 61.42 21.00 4.00 4.58- j **# - Binder: UCAR Latex 131 (Union Carbide).......................... ..................... t--6 c 6.60' - . Workability Control Agent: CELLOSIZE Thickener, TJC Grade (Union Carbide)................ 0.50 . --; Drying Control: - Ethylene Glycol (Union Carbide).................................................. /. => 1.00 # nT Defoamer: "Nopco" PD-1 (Nopco Chemical Company)............................. f\ _ 0.10 Dispersant: "Daxad1' 30 (Dewey & Almy Chemical Div.).............................. 0.60' Bacteriastof: "Dowicide" A (Dow Chemical Co.)............................................ Total Water: about 56 parts by weight per 100 parts dry solids a 0.20 100.00 fc *Contaiieci solids basis UC TrJ, crS 5 iJ 2 -CAL1DR1A" ASBESTOS SG-130 ANO SG-210 For Tope Joint Compounds Typical Product Characteristics Reflectance (G.E. Photovolt) .......................... Contained magnetite ..................................... .. Alkalinity (as % of HajO) ................................ pH (5% aqueous slurry)...................................... Surface area (BET) ............................................ Oil Adsorption (DOP ?/100# asbestos)......... Wet Bulk; settled vol. (ml.) lGg/250 ml./l hr. Dry Bulk (If/ft.3) .............................................. Water absorption (wt. % in filter cake) .......... Size distribution (cumulative % retained) Wet Screen mesh size 100.................................................... 200 ............................................ ... 325 ............................................................. CALIDRIA Asbestos SG-130 | SG-210 68% 2% max. 0.05 to 0.06 8.5 to 9.5 50 to 60 m^/g. 90 to tOO 200 Zto8 . 55 lo 60 U0 to 120 220 5 to 6 62 to 65 5 17 28 to 32 Trace 3 10 ro 15 Packaging and Shipping Information Product Form -- Opened (finely ground) chrysofile asbestos fiber. Packaging -- " One Package................................................................................. Pallet Weight Carload ................................................................................... Truckload..................... ........................................................... Shipping -- Classification -- asbestos shorts Rail point of origin -- Welby, California (King City, California) CAUDRIA Asbestos SG-130 SG-210 40 lb. 30 1b. 1,600 lb. 1,050 lb. 2,000 lb. 1,500 lb. TOXICOLOGICAL PROPERTIES It has been known for many years that some persons working in asbestos produc tion were prone to develop a disabling lung disease. In time-, this condition became known as asbestosis and was related to exposure to high concentrations of asbes tos dust. With further experience, it was found that men could work with asbestos without development of lung disease if dust concentrations were kept below a certain level. It is now generally accepted that a man can work a 40-hour week for a lifetime without developing asbestosis if the asbestos dust particle count is kept at or below 5 million particles per cubic foot of air. This dust concentration of 5 million particles per cubic foot of air is the Thresh old Limir Value for asbestos, and no cases 3 "CALIDRIA" ASBESTOS SG-130 AND SG-210 TOXICOLOGICAL PROPERTIES (Continued) of asbescosis are believed co have occurred when exposures, have been maintained at or below chis level, despite large-scale utilization (now approaching one million tons per year in the U.S.A.)- This concen tration of dust is generally not visible in the average work area unless a beam of light causing a Tyndall effect is present. Usually the dust concentration must be from 8-10 million particles per cubic foot before its presence is visible in average lighting conditions. Several years ago, ic was reported thac there was an increase in the incidence of cancerous cumors, especially of the lung, associated with asbestosis. Recently chere have been reports of some cancers occurring in individuals exposed co asbescos dusc, buc who have noc developed clinical as bestosis. It is believed by most authorities chac these cases have been associated with exposures significancly exceeding che Threshold Limic Value. A major manufac turer of asbestos produces who also mines asbescos has not been able to show an in crease in cancerous growths in men work ing where dust concentrations were main tained at the Threshold Limit Value. Control of asbestos dusc exposure is therefore necessary. The control methods are the standard ones applicable to a variety of duscy operations. They include closed flow systems, wee processes where possi ble, and adequate exhaust venciladon where openings in the system are necessary. Pelletizing is sometimes used co improve the handling characteristics of otherwise dusty materials. Where satisfactory con tainment to scay wichin the Threshold Limic Value is impractical or impossible, effi cient and reliable respirators are available for che protection of che employee. A pro gram of environmental monicoring in manu facturing operations is highly desirable co determine chac Threshold Limic Values are noc beiag exceeded. Employees should wear respiracors where dusting occurs in finishing produces such as sanding taped joints. Pre-employment and periodic physical examinations of workers are desirable. These should include chesc X-rays co in sure thac the worker has no chesc con dition prior co work with asbescos and to determine that no lung changes are result ing from work wich asbestos. In conclusion, while asbescos dusc in excess of che Threshold Limic Value is pocencially harmful, as are many other dusts encountered in industry, it is as readily controlled as other such dusts and it can be used safely with appropriate precautions. 4 CAUDRIA" ASBESTOS SG-130 AND SS-210 For Tap* Joint Compounds RELATIONSHIP BETWEEN WATER & OIL ADSORPTION CAPACITY OF SOME ASBESTOS PRODUCTS .-FOR TAPE JOINT ADHESIVE FORMULATIONS s THE DISCOVERY COMPANY *1* Safes Offices . UNION CARBIDE CORPORATION CHEMICALS ANO PLASTICS 270 PARK AVENUE. NEW YORK. N.Y. 10017 Unitsd Slatas A, I'lfiStBS ATLANTA, GEORGIA 30309..................................... 1371 Peachtree St, N. E. .. 1..______ .404-892-7300 BALTIMORE. MARYLANO 21207.............................Beltway Bldg.. 6707 Whitestone Rd._____301-944-32U BOSTON. MASSACHUSETTS 02194...................... 300 First Ave, Needham Hgts................. 617-444.5400 BUFFALO. NEW YORK 14223................................. 3343 Harlem Rd.........................................716-837-6450 CHARLOTTE. NORTH CAROLINA 28210................. 6230 Fairvfew Rd...................................... 704-364-1400 CHICAGO. ILLINOIS 60606.......................................120 South Riverside Plaza........................ 312-822-7000 CINCINNATI. OHIO 45227....................................... West Street and Madlsonvffle Rd..............513-272-0206 CLEVELAND, OHIO 44114........................................1300 Lakeside Ave, N.E...........................216-621-4202 CLIFTON, NEW JERSEY 07012................................ 93S Allwood Rd......................................... 201-778-2900 DALLAS. TEXAS 7S207............................................ 2710 Stemmons Freeway..........................214-631-0010 DETROIT. MICHIGAN 48221.................... ................10421 West Seven Mile Rd.. ..7............. -.313-341.3131 HARTFORD. CONNECTICUT 06103..........................410 Asylum SL.......................................... 203-525-9345 HOUSTON. TEXAS 77027........................................ 3839 West Alabama Ave........................... 713-621-1000 INDIANAPOLIS. INDIANA 46220..............................720 Broad Ripple Ave................................317-255-31B1 KANSAS CITY. MISSOURI 64141........................... 910 Baltimore Ave........................................816.221-2400 LOS ANGELES. CALIFORNIA 90058.......................2770 Leoros Blvd........................................ 213-583-3061 MEMPHIS, TENNESSEE 38116................................338S Airways Blvd.......................................901-396-5375 MINNEAPOLIS. MINNESOTA 55416 ........................ 3033 Excelsior Blvd.....................................612-927-4221 MOORESTOWN. NEW JERSEY 08057 .......................Route 38 and Pleasant Valley Rd..............609-235-6200 NEW YORK. NEW YORK 10017................................ 270 Park Ave................. .......... 212-551-4641 PHILADELPHIA (MOORESTOWN. NEW JERSEY SALES OFFICE)................................................ 215-923-3200 PITTSBURGH. PENNSYLVANIA 15220................... P'kway Center. 875 Greentree Rd...... .412-922-5700. ST. LOUIS. MISSOURI 63105.................................. 10 South Brentwood 8!vd........................ 314-7264)324 SAN FRANCISCO. CALIFORNIA 94106................... 22 Battery SL............................................ 415-982-1260 ' SEATTLE^ WASHINGTON98118 ...............................4726 Rainier Ave, South...................... 206-723-8660 TULSA. OKLAHOMA 74114................................... 2901 South Harvard................................ 918-742-5524 Pan America ARGENTINA ___ ________ Union Carbide Inter-America. Inc.. Buenos Aires BRAZIL_______________ _ Union Carbide do Brasil S. A, Sao Paulo. Rio be Janeiro CANADA ....... Union Carbide Canada Ltd.. Calgary. Lachine (P.Q.), Toronto. Vancouver. Winnipeg CARI88EAN__ ,_________ __ Union Carbide Inter-America. Ina, San Juan, Puerto Rica CENTRA!, AMERICA....... alir Union Q&ehid* Infnr.Amanea, tne.. Panama City, Panama CHIU _______________ ;_ Union Carbide Comercul Chile Ltd.. Santiago CMtOMRIA...................... Union Carbide Colombia* S. A.. Bogota `VMEXICO_______________ __ Unicart) Comerdal. S. A. de C. Mexico. 0. R* Guadalajara, Monterrey PERU ........ . .. Union Carhid* Intaf.Ameriea, lne.r lima VENEZUELA___________ __ Union Carbide de Venezuela. C. A, Caracas WESTERN HEMISPHERE __ Union Carbide Inter-America, Inc, New York. N. Y. Eastern AUSTRALIA__________ _ Union Carbide Australia Ltd, Sydney, N. S. W. HONG KONG __________ __ Union Carbide Asia Ltd, Hong Kong INDIA ........ .... Union Carbide India Ltd, Calcutta. Bombay, Madras, New Delhi NEW ZEALAND.......... Union Carbide New Zealand (Pty) Ltd.. Auckland PAKISTAN National Carbon Co. (Pakistan) Ltd., Karachi PHILIPPINES Union Carbide Philippines Inc., Manila SINGAPORE-___________ __ _ Union Carbide Singapore Ltd, Singapore Europe |Midala Ease, jnd norm Africa t / AUSTRIA_______________ Union Carbide Austria Gas. mbH, Vienna BELGIUM___ ,,. __ Union Carbide Belgium N. V, Brussels FRANCE ____ ' __ Union Carbide Europe s.a, Succursale Francaise. Puteaux-Paris GERMANY __ Union Carbide Deutschland. GmbH. Oussefdorf ITAIY ....... Union Carbide Italia S.p.A, Milan MIDDLE FAST .......... Union Carbide Middle East Ltd.. Athens. Greece NETHEHLANCS________ __ Union Carbide Belgium N. V, Amsterdam SCANOINAVIA ....... ....... __ Union Carbide Noraen A.S, Stockholm. Sweden SPAIN_________________ . - Union Carbide Ibenca S. A, Madrid SWITZERLAND________ . Union Carbide Europe s.a,, Geneva UNITED KINGDOM_______ Union Carbide U. K. Limited. London. Manchester. Rickmanswartti; England Africa AFRICA (EAST) ......... __ Union Carbide Afnca Ltd, Nairobi. Kenya AFRICA (SOUTH) --------- __ Union Carbide South Afnca (Pty) Lid, Johannesburg. Capetown. Durban; Republic ol South Afnca