Document RaJ16MRB7j9we2VQoNEN53bk7

PROPOSED RULES .duhtlin tf time * * The authors Mb 1975 (23), Dr. H. P; Krayblfi. chair \sugg$st t|t the use, of smekUhii and man, states that: : ,,F..._rw__ ,,__ _________ ____ fit Defeat- p^to tn^wblehdldiiotdlreetlyfovqlTes worker exposure to asbestos, but lotherpgtehtagcompoundst^Siin*, fandsandtogand cleanup operations), may expose u user and other members invectigatms luHfas *hd of CMcinogoneslv here doubted tts extttsnco ol threshold . tor carcinogen or at least bare maintained In which thcrehad been occastanalop- .of .the hotwtdboldto" significant -that: thereat* no aesSptabla pmoeduret tor portunlty for exposure merely hyvirtue concentrations of asbestos". otworktog intbeaame ereaa.ThiBarlgl- Asbestos in the household presents a nal finding tub been widely confirmed great; risk due to the presence: hi the and: numerous cases of mesothelioma I household Ofpersons,such aa children, have since been reported informer ship I who may be particularly vulnerable to yard workers (WlhteweUand Eawcllffe. carcinogens. It is generally observed esHSBnuUtf of s atfe-domfor: a carcinogen (I*. threshold). Thus, It has tan concluded that, U is hot feasible to prove or disprove the preMnoror Absence of a threshold-dose through downward, extrapolation from the dose-response curve in regions of detestably dgniacanVdoeage. Tfce conservatism In this 1919 <809 V; MCBwtUi eVat ieTt) <37)>; that, because of the long latency pbrtodi direpttch is prompted by certain^realizations Stumphius, im () ; Greenberg and Darin, 1914; (16) . Btudiesof popula tions of current shipyard workert) hare shown much radiologlcalevldeneeof as- exposure to inhalabte asbestos in the some cut he llfe-shbrtehtog for children. In thfeoormedtlun. Dr. Paul $ot1hof the Johna-Manvllle Company, stated to ah OSJPIA; Advisory committee, .that to hi* iabomojTexpertence.canc^' can be to to tha aelf-repllcatlng natnre of the. eahcer oen, tkp posMble cxlatcnca of lneveralble cflects. the acpccta 61 lasting alteration lnduoed by.a tumor-producing event, the per petuation of the neoplastic lesion after the octitnal-inducer -haa disappeared from the milieu/; and Anally, the paeslbiuty of eancer most readily Induced to the young (14).. IntHoUm from a mutation In a eomaUe oeli. <4);Fietcherf 1972,ilM). Further, evidence hits Indicated that asbestos also acts as a lung oarclnogen at levels, much below those which will pro duce asbestosis, Two surveys of shipyard workers who had X-ray evidence ol pleuralplaques, butgenerally notof pulmonaryflbroais, showed a a.5-fold ex cess risk ol death from lung cancer and high risk of mesothelioma. (Fletcher, Tills ptont was further ctarihed at a'' briefing before the Commission on-Jttne' 9, 1977 durtogwhlch Dr. Kotin stated his belief that the young are doubly vul nerable to carcinogens--first, because of a long lifetime ahead and secondly be cause young children grow at a more rapid rate than adolescents, Thu#/he ex plained. rapidly dlvtding cdh a cell which hae a. turnover i These tbeomUcal oonoepts have a bearing: on the asbestos issue,, particu larly as the iiuesUon of the existence, or nonexistence; of a threshold level of car cinogenic effect. A "no effect" level theoreUeally may exist, hut It has not beeni demonstrated. Therefore, there is no>'* kopwn tiuresheld level below which ex^ poeur* to resptrable free-form asbestosi would he oqnaidsred safa lBTfe <) ; 5d|e;;4OTi'<|rg Sb a gfcdr ol the martaUty experlence of aj large VS. asbestos products manufacturing fa cility, it wits found that workers in low dust areas, with a minimum risk of death from asbcstoslS, had the same high risk of death from various cancers as work ers in dustier areas (NlcholBon, 1976. (33)>. It Is extremely difficult, if not impossi ble, to document brief exposures reported to have occurred 20 of mine years before the ohset of symptoms. To determine the type and extent of non-occupattonal ex posure, the investigator must generally rely on relatives or persons other than the exposed patient for exposure history. ... (Much of (to- 10T62oli9ftM(ffnaUib ir\ pfi&v pared by the OccupatidnaTSafety and Health Administration (OSHA) and pub lished at 40 FH 47651, October 0,1070, "Occupational Exposure to Asbestos" has been helpful In preparing this proposal more likely to be subject'to the action of . OTHEH pEDhttl AOBIICr ACXXOBS TO acoRdnogen." HXaULaTS KSFOSDSC TO ASBESTOS Tbs' posure Commission concludes to asbestos from, either that ex patching . The Occupational Safety and Health Administration of the Department of compounds or artificial eraberiztag ma Labor (OSHA), the Pood and Drug Ad terials presents an unreasonable risk of ministration (FDA) and the Environ injuty. sufficientthat either product mental Protection Agency (EPA) each standing alone should be banned; The has a responsibility to regulate exposure Commission also notes that consumers to asbestos.' are exposed to asbestos from sources OSHA regulates exposure to asbestos other than the products proposed for by workers to allindustrial and commer banning. The asbestos fibers are present cial settings except agriculture. The reg to the general environment ha# been ulation (29 CFR 1910.1001) states that demonstrated by studies such ad those by the 9-hpur time-weighted average air Huff (21) , Selikoff, and Harwood (38). borne concentrations iff asbestos fibers Consumers who are exposed tp asbestos to Milch any employee may be exposed . shaQnotexceedtwoflher3,longer than 5 . .................. thus rooelveadUl- adorametom, her cubic centimeter ef oiir. Uonal aaMs of asbestos and can be pre-: In lOTS, OSHa proposed an amendment sumed to face a greater risk thahman- to lower expoeure to S fibere per ctlble bers of the population who ape not so centimeter Of breathing air. An OSHA exposed, *nd a greater cumulaUvertsk pntoasal to regulate exposure fag workers than if ho asbestos were present in the in the building construction Industrie; Is':expected tore ready for publication )). / A bibliography of additional /wdenilfle wlthto the next few months. coHsunma xxrosox* i and medloa) literature reviewed by the FDA has banned the use of asbestos to Reports of the haxaid, or potential tor ICommission is noted; below and an an- filters used to the formulation of paren harard, from exposure to asbestos result- Inotated bibliography is available for re- teral drugs (21 CFR 2U.40(J and, tog from use of asbestos-oontainlng can- Wtew to the Office af the Secretary; prior to the establishment of the Con aumer products are ve'ry tonlted. The only known quantitative study of ashestea levels to products regulated by this "thmshow" insw -v...-/.. , ^.. ... . Because of the variability of Individual sumer Product Safety Commission, banned: the use of asbestos to fabric used for general wearing apparel. <16 Commission was reported by Rohl, et al response to carcinogens and other fac- CFB 1500.17(a) (7)9. (1975 (36)), oi asbestos fiber conoen- tore, the concept of a. "no effect? or EPA regulatea asbestos which is re trations measured during the use ot-^threShold level" of exposure may;have leased: into the airland into the water. consumer spackltog patching and raping little real significance on the basis of These regulations <4d CFR 01, 427. 430) compounds. This study, indicated that existing knowledge, While soma level, do hot set stuidards for allowable airborne fiber concentrations, exceeding below which exposure to a carcinogen amounts of asbestos in the breathing air the interim OSHA allowable excursion, does not cause cancer, may conceivably but rather minimize or eliminate emis exposure level, were detected during ap exist for any one individual, other in sions from industrial locations. Thvso plication and cleanup operations, fibers dividuals may have oancer Induced fay regulations specifically prohibit the pres were detected in adjacent reams during mixing operations and It was reported that significant concentrations of asbestos remained suspended and eould doses so low as to be effectively tern (35) . In the Proceedings of the Nineteenth Meeting of the interagency CaDabaraUve Group on Environmental Carcino genesis devoted to Threshold Evaluated ence of asbestos to emissions from plants manufacturing- materials far use in building roadways and to manufacturing Items such as olotb. textiles; cement,fire proofing ami friction products, paper; pervade living quartern for a considerable held at the National Institute oh August felt, floor materials; paints, adheUvcs, nciSAl SEOISTU, VOL 41, MO. 146--fSIOAY, IUIY If, 1477 ,\ 8001 00?} 'i r- p*0,'** HFM- 003369