Document RakbveYQeyw8xqEj5eroROE97

V."J ..,.._.., " ' ' 1 1 ' - 1 .._,,._'-' .......,, , '-~ ..- ., I'PCB H~ARJNG CHICAG0 1 OCT, 151 197/ J. .Thank you very much for the oppor~uni ty to appear in support of your.regulations controlling the use and production of asbestos materi- .: als and spray insulation. For purposes of i?entification, my name is William J, Nicholson, I am Assistant Proi'essor of Community Medicine at the Mount. Sinai School of Medi.cine of the City University of New York. As a physicist, ' I -have 'served as coordinator of several projects undertaken by the Environmental. Sciences Laboratory of Mount Sinai to evaluate the ef- fects of asbes~os exposure. These include an industrial hygiene.re- search program desi~ed to identify and control asbestos hazards in the insulation industry, the development.. of analytical techniques for the quantitation of asbestos in ambient air, and a study of asbestos air pollution in New York Ci.ty and throughout the United States. Addi- tionally, I am engaged in several epidemiological studies of disease as- . .. sociated with occupation or environmen.t~l exposures to various substances . '' ~vo of these studies invoive the effects of asbestos on defined popula- 1. i tions, The justification is strong for controlling the use of asbestos on basis of the health effects produced by its use in the past~ The evidence that heavy occupatiorial exposure to asbestos is associ! ted with pulmonary disease dates from 1900 when massive fibrosis was found at post mortem in the lungs of a man who was the last surviyor of a group of 10 men who worked since 1886 in the carding room of an asbestos textile mill. Cases of asbestos-induced scarring of the lungs, asbestosis, were seen with increasing frequency in subsequent years as the use of asbestos in- creased, However, a hint of additional disease risk from occupational asbestos exposure was seen in 1935, 'J.Wo cases of lung cancer were found in individuals having asbestosis. Thls po:~,tent w::~s grimly vC?rified in FMSI 06459 . ' later studies. In 1947, the Chief Inspector of Factories in Britain found lung cancer in 13 per cent of deaths in which asbestosis was present. To bring us_up to date, 70 years after the first knowledge of as- bestos disease, and to-'complete the picture of occupational risk from expos~re to asbestos, let me present some data obtained by Dr. Irving J, .Selilmff, Direqtor of the Environmental Sciences Laboratory, Mount Sinai .School of Medicine. He has followed' since J~nuary 1, 1943 the 632 ' members of the New York and New Jersey Locals of the aspes.tos workers union, the International Association of Heat and Frost Insulators and Asbestos Workers. These men apply the insulation to high temperature pipes and boilers in apartment, office building and individual plants. . Some of the ;.;;-;tori~l they u::::e co!!tfdr.s !" small amount of asbestos -- 7 to 15 per cent, usually, Often it contains none, ln compaTison to the factory exposures during early decades of this century, their exposures are relatively light. }~owing their ages in 1943 and using standard tables, it was poss- ible to calculate the expected mortality experience of t~ese 632 workers. This was done .by Dr. E. Cuyler Hanunond, cp.ief Epidemiologist of the Ameri- can Cancer Society, and the results, along with 'those actually seen, are given in Table I for the years 1943 through 1962, From all causes, 203 deaths were expected of those who had worked 20 yeal;'s. In fact, ther~ were 255. More than 50 men who died should , \ not have died , Lookingat the table;-we can see the causes of these . " exces.s death tl : 45 died of canc. er of ~ho. .l u n g , ~rnchea . and pleura where .. FMSI 06460 ., should have died; .three times as many ~ied of cancer of the G. I. tract as were expected. ., .. Results of continued observation of the group through June 301 1971 are shown in Tables II and IU. They represent a catas.trophe. OVer half I of the deaths were from some form of cancer or asbestosis. Nearly 40% . could be termed " o c c u p a t i o n a l 11 deaths. !' lri these latter data, special reference should be made to the high. death rate f~om mesothelioma. Twenty-seven case~ of this, as yet, in- i c~rnblc disco so woro soon. A diffuse cnnco,.- of the lining of tho cheat or abdomen, it is so rare that it has yet to be separately classified in the International Classification of Causes of Death. Its occurrence in the general population may be so infrequent as to cause only one death in 10 1 000. Here, it was the cause of death in one of every .~6 individuals. Moreover, in other studies, its appearance'in-increased amounts has always been associated with asbestos exposure. Two other aspects of the research by Doctor Selikoff are important. The first is the evidence of the long lapsed period between onset of . asbestos exposure and the incidence of disease. Lung cancer usually appearsbetween 20 and 40 years after first exposure to asbestos, and mesothelioma most often after a 35-year lapsed period. The second aspect is the strong synergism found between asbestos exposure and cigarette smoking in the incid~nce of lung cancer. By personal interview in 1962, the smoking habits of 370 of the 632 men were established. By following the mortality experience of these 370 men, a' special risk of cigarette smoking was established. From January 1, t963 thrl:>ugh February 1, 1971, in 283 .men with a history of cigarette smoking, 40 lung cancers were observed. TI1is is nearly ten times the number ex- FMSI 06461 pected in an equWalent cigarette smoking population. In 87 non-smokers, only one lung cancer was seen. Thus, it is not asbestos alone, or_ cigarette smoking alone, but the combination of the two that produced these grim data. In _fact, it is calculated that asbestos workers who I smoke run more than 90 times the risk of dying of lung cancer than men who neither smoke cigarettes nor work with asbestos. These data I have presented to you were from occupational exposures to asbestos . At most, 200,000 men and women in the United States have such exposures. Hopefully, 70 years after the first sr.vareness of asbestos.: disease, working conditions will be improved to r~duce their risk of disease. But were this the only risk of asbestos exposure, it would not be germane to the regulations under consideration here. Unfortunately, in recent years the evidence-has accumulated that the proble;m of asbestos disease has disseminated from the occupational area into the general environment. Evidence is accumulating that mesothelioma is rapidly increasing among men who worked in tho vicinity of asbestos application. Recall. that mesothelioma is virtuaily nonexistent in people who have had no exposure to asbestos, In Holland, 22 cases were found during a 6-year period in workers of the de Shelde shipyard. These cases oceurred, however, not in asbestos workers,_but in members of other trades, welders~ carpenters, or painters, all of whom only wonked in an area where asbestos insulation was applied or removed, Similar data have appeared from Great Britain. Here, 80 cases of mesothelioma were found in a survey of the material in the pathology departments of Scottish hospitals and medical schools from the _year~_l950 "through 1967~- An investigation of the occupational background of these cases revealed o strong association I. FMSI 06462 '' .. with shipbuilding.or marine work. Here again, however, the cases were ' not often found in insulators but in other trades working near the f . application or ~emoval of ' asbestos. A further disconcerting feature .of the Scottish data is the rapid rise in the rate of occurrence of I mesothelioma; 51 of the 80 cases were seen in the years 1964-67, ap- .. proximately 30 years after the extensive shipbuilding undertaken during World War II. The spectrum of disease associated with asbestos now extends even to environmental exposures. In 1960, Wagner,: Sleggs and Marchand des- cribed 47 cases qf mesothelioma found during a four-year period in the northern Cape province of South Africa 1 .an area with extensive crocidolite a~;>bcstos mines. None were seen in the neighboring Transvaal Province or in 10,000 autopsy cases of workers who had died with known exposures to silica. Of the 47 cases, approximately half.were found to have had either industrial or mining exposures ~o asbestos. Virtually all of the remaining cases were in individuals who simply lived or worked in the vicinity of the. asbestos mines or mills. Confirmation of the possibility of environmental asbestos-associated diseasesoon appeared, Newhouse and Thompson reviewed all mesothelioma . cases at the London Hospital, They corroborated the close .association with asbestos, 31 of the.76 cases having had documented occupational exposure, Of the remainder, 11 had lived, dycades before, within oile-hnlf mile of an asbestos factory. A similar distr.ibution of cases was found by Lieben and Pistawka in Pennsylvania, One insidious form of indirect ' asbestos exposure is that of families of asbestos workers. In the previously mentioned studies, 9.o~ the ~ondonmesotheliomas were in family _; members, .as were 3 of t.he 46 Pennsylvania cases. FMSI 06463 Unfortunately_, those data on the incidence of mesothelioma from environmental or indirect occupational exposure to asbestos are severely limited. The exposures in question took place beginning 20, 30, 40 or more years ago. No lmowledge exists of the associated asbestos dust I exposure levels. Thus, we have no dose-response information on lowlevel asbestos exposure. We only have lmowledge.of a potential risk of cancer, at exposures much below occupational ones. Obvi~usly, additional research and continued surveillance are highly desirable. Let"us now turn to specific items in your regulations. Firstly, the general requirements of paction 2 are excellent, particularlywith regard to responsibility and education. We find a great problem to be the ignorance of a potential hazard among marginal users of asbestos. Such ignorance can easily result in lax procedures. Secondly I the banning of asbestos in spray 'insulaiiOil i:s ellt.i.r.:.ly appropriate. In New York City we have found this to be a major contrib~tor to ambient air asbestos levels. For the past 10 years,.during which spray fireproofing came to be extensively used, it was not uncommon to see extensive snowfalls of asbestos-containing material ~ver widespread areas of New York and other metropolitan centers. In some cases, the fireproofing was even done with no attempt to enclose the spray area by tnrpnulina or othor menns. 'l'o vorify thnt such fireproofing opornt~ons woro o significant source of respirable asbestos fiber, air sampling: was conducted in lower Manhattan about construction si~whe1eextensive spraying of asbestoscontaining fireproofing was taldng place. This work was done by our Labora tory in conjunction with tlw,_ Department of Air Resources of New York City. The results demonstrated that spray fireproofing can indeed con- l. FMSI 06464 l I tribute signifi~ant~y to asbestos air pol~ution. I Up to 1 mile away 1 levels exceeding 0.1 microg.rams per cubic meter were observed, which exceeds by 100 times background l~vels found in urban areas distant from construction sites. While 0.1 micrograms may appear I .I to be a small amount, it could represent more than 10 million minute . fibers of asbestos. Moreover, the large clumps of asbe~tos-containing material covering the sidewalk serve as a continuing S?urce to be dispersed by passersby. As I mentioned earlier, lacking a dose-;-response relationship, we cannot state that envi;ronmental exposure levels from this practice are certain to produce disease. However, it is hard to imagine factory emissions, even 40 years ago, being more excessive. Since the extensive spraying of asbestos-containing fireproofing material has only existed in the construction industry for the last lO years, disea.se cau~eu Ly the exposure resulting from this practice is 10 or 20 years away. How- ever, continuing the uncontrolled spraying practices of the_past decade in the face of the mounting e~idence of risk to all metropolitan residents would be playing asbestos roulette with the lives of millions of people. This method of fire protecti?n for high rise buildings presents an additional, continuing risk to the occupants of those buildings. Often, the space between tho false room coiling on~ the under side of the fldo~ nbovc, whfch has been sprayed with asbcstos,,sorves os o return plenum for the air supply system. After filtration, inadequate to remove most as- bestos fibers that may have eroded into the air stream, this return oir is recirculated throughout the building. The magnitude of this problem has yet to be defined. Until rece~tly_ in New York City., we have not been allowed to analyze the air in buildings that has been in direct contQct FMSI 06465 with n'sbestos-con~ain:J.ng insulation. Finally, this spray procedure leaves o legacy of potential risk to future generations. The lifetime o~ modern office buildings is short and the procedures for .the safe future demolition of buildings that could I contain more than 100 ton~ of asbestos as fireproofing have yet to be devloped. Perhaps these procedures will be fou~d and perhaps they will .. be followed but we have no such assurance at this time. Unfortunately, safe procedures developed for the spray application ../o f. asbestos-containing materials have not been followed either voluntarily ofor under control regulations by contractors. Because this failure and because alternative procedures or materials are available, action banning this 'use or' asbestos is indeed approp.riate. Moreover, because of uncertain knowledge of the health effects of ex- posure to mineral fibers other than atiuestos, it is enti:.cly npp:::-op:::-i:'!te that strict control be exercised over other spraying of such substitute materials. While some forms of "mineral \'iool" and other mineral fibers have been in UP9 since the 1930s there are still no definitive studies on exposed populations that would, at this time, provid~ assurance that respirable mineral fibers, other than asbestos, are biologically inert in :I i: il humans. In the absence of such assurace, caution is warranted and I 'II, I support, in its entirety, Section 3 of your regulations. On the.other items, in Section 4 1 you mtght wish to add a qualifying .statement that when there is potential release of asbestos to the air, a special enclosure shall. be used. Many asbestos products used in con- I structi~n can be installed with no release of fiber. Asbestos-vinyl. floor l :I tile is one example. In fac:::t, ~i.th proper procedures 1 even .asbestos I cement can be applied with minimal release of fiber. .l II I l I FMSI 06466 9 lI , t I''1-I il :i II 'I I ' '! I. l. . I cannot cmp~asizc too strongly tpe need for stringent controls during demolition. Those listed here may not be adcqua te and .closo sur- .: . veillance should be maintained to verify the~r adequacy. For example I 1 am not sure that any ~sbestos should be transported via chutes to trucks. .I It is hard to imagine that the debris would be completely wetted. In reference to Section 6 A, I would like to raise .some of the problems .. assoca"ted with air monitoring which.may be severe. In ambient air samples, it is diffic~lt~ and often-impossible, to identify asbestos fibers by optical micro~copy alone. There are many b'irefringent fibers with .. a simi- lar appearance. Even the sampling of stacks containing only asbestos has its probl-ems.; Such sampling does not evaluate any emissions from window~, room e~hausts or uncontrolled sources. Moreover, the use of optical microscopy can mise9timate actual concentrations, e~~n assuming .' accurate counting of all fibers longer than 5 microns. Often as many as 100 times more fibers shorter tha!l 5 microns m~y be pr.esent. If those counted were a constant fraction of the total present, this would be no problem. However, such is not the case. In different uses of chrysotile we have found the ratio of the number of fibers longer than 5 microns to the total number to vary from 1/250 to 1/20. Since bag houses have a size dependent efficiency, the results obtained by optical ailalysis may be misleading and not .comparable to other samples analyzed by. similar means. .' The only way to accurately as.ses environmental exposures is by electron microscopy. Here, however, an analysis may cost $200- $300 ' and be ver.y time-consuming. You may wish to consider procedural controls with the requirement of no visib~e. emissions of asbestos from any building or site. If the facility inspected questions tbc judgement of on inspector they could pay for adequate air analysis by electron microscopy. FMSI 06467 ~ enclose in Table IV data from our work analyzing samples of ambient 'air from nearby 50 u. s. cities. TI1ese data. show that a background of some asbestos fi~er is found in all cities, but occasional peaks appear. From this occasional occunence and from the fiber size distribution on high I samples, it appears that the contribution of some specific source is important in ~hese high levels. Finally, one comment on the proposed ban of asbesto:Ei in brake linings after: 1975. The problem here is there is a dearth of information. We have somevery preliminary informatiop th~t asbestos air levels near .I sites of extensive braking may be 3 times higher than background. Since wind conditions are highly variable, much more analysis of this question is required. All our data really show is that brakes are not as obvious a problem as asbestos-containing fireprooofing spray in New York City. Perhaps you may wish to qualliy 7 B by the words "Unless evidence of safety is demonstrated tho usc of nabostos., " In su~nory, your regulations in general oro oxcellont, your intent is proper, and I_am pleased to support you. .L -1 I ' FMSI 06468 r~rfHi ~~l 1i ~p,,-,, i !l !I 'l !1 :l !~ "i ~ i. ;; il l ' ; I l l I I I I i t i' i. I: l I., H. I ! l I Il t I l i' i t ~ ~ l t I 1 i 1 i ... Table I Observed and Ex~ectcd Number of Deaths Among 632 Asbestos Workers Exposed to Asbestos Dust 20 Years or Longer, ]943-1962 ... . . . Yea]."s.._ Cause of Death Total, .nll cnuscs .. ...... Obscivcd (nsbcstos worl;;crs) Bxpcctcd. (US whi to males) 19431947 28 39.7 1948- 1953~ H152 _19_5_7, ,. 54 '85 .5.0 .8 I. 56,6 Total cancer, all sites Observed (asbestos viorkers) Expected (US wl}i te rna les , 13 5 ,7' 17 8.1 26 13.0 .Total, 1958- 19431962 . 1962 88 . 255 54.4 203,5 39' 9.7 95 36.5 . -~ . . ... Cancer of lung and pleura . Observed (asbestos worlwrs) Expected (US white males). 6 8 13 18 45 o.s 1.4 2.0 .. 2.4 6,6 s~nccr of stomch, colon and !'rectum . ~ Observed (asbestos workers) Expcc ted (US white males) 4 4'' 7 14 29 2.0 2.5 2.6 . 2,3 9",4 C~ncer of all other sites combined ... ~ ................. Observed (asbestos workers) 3 5 G 7 . 21 Expected (US white males),, : .. 2.9 4.2 8.4 5.0 20.5 ..Asbestosis ~ Observed (asbes~os workers) 0 1 4 7 12 Death rntes as reported annually by the u.s. Nat~pnal Offl~c of Vital Statistics. A five year overage is given here for each period. ., Ocath rates in9ludo cancer of lung, bronchus, pleura, mediastinum and trachea, assigned to international listcod~ No. 47b-f prior to 1949 and to No. 160-164 thereafter. ... .. . ... ..... -. .... _,. ........... . I. .. .. ,, . , ....... ..I ... f.: .. ~- ... . . f, ... .. ...<' . .c, . .:.... ! FMSI 06469 .. ..,. i I. .. .. .. .. ... : Table II ;.,.. ~ I . I .I f. : El\pcctcd and observed deaths ;u"':long 370 ~rsbcstos : I insula-:;ion worker.s, Ja:l, 1, 1963 J'U?a 30, 1971. ....... ..... Observed. :Ehpcctcd deaths de<!ths .Tot~l cunccr (all sites) 92 ." .15 .1. ... ::<., ., . ," . C~"lccr of lu::::g, pleura, trachea, bronchus .'. 47 ~"'5 Lung'c~ncc:::- .''43. - .' :, ,PlcUl:.al ncsothclioma .; ......:~. .:/ , .:~.....,'\ .'4. .. Pcrito::'lc:::l ncsotholio:na . :.: '' '.:.: ..:~ 19 -. .. ~ Car:ecr o~ sto:nach, colon. and r9ctum:: -::..... : .. 12 Cancer all other .sites ::- 14 + ""'"'++ 3.0 ~ '7 .6 ,.. . : .Asbestosis . .. All other causes 20 ~ ~. + .51.''\ 63,5 Totul dcnths. . .~ ...;;i. ..,),~~ ..7S,6 >i<D-:p'.::c'!;cd deaths oro based upon !:.go specific rates for U.S. ".~ :. w!;i tc moles in 19S7. Smoldng habits arc disregarded . ~ -'.-United States data not availnblo but :fir;ura .should bo only . ': slightly less than 4.5. .i ... . ... ... j: I I. ~ ., ;l I. :: ~ : : , ' f.. ._,,:. ~ .. f . I'. . ..... ..... .. ... . 0 .... . . . -~"'I o .... o 0 ' : . .. ... '.' . . .,... .. .~ . ., ... .. .. .... ...... .......... .. . ............ ... '. . .,..;~- .:, ' : .:..::....-.~. . .' r.... ... . . ; .: ~ . " ....1.. .I. : .: : ~ .~... ::~,_ : ,.. f o :: . "':. ' ,, . .' ' ...... . FMSI 06470 - - "------ -..-----. Table 111 Mor~ality e~perience of 632 members of lAHFlAW, Locals 12 and 32 January 1, 1943 to June 30, 1971 '. '~ I l \ I I Cause of Death Lung cancer Pleural mesothelioma Peritoneal mesothelioma Gastro-intestinal cancer .. All other cancers Total cancer = 188 Asbestosis All other causes ;- I Number 85 7 20 40 36 Per Cent 20.0 1.6 4.8 9.3 8.4 32 1.7 205 48.2 425 100.0 --- --- -~ ... Table IV Asbestos Air Levels in United States Citie~ Analysis of 187 Quarterly Composite Samples Asbestos Air Levels oo-9 grnms/m3) Number of Samples With Given Vaule \ 0.0-0.9 61 1.0-4.9 103 \ 5.0-9.9 12 i .I i 10.0-19. 9 8 I I r 20-49 2 ! 50-99 .. 1 ~ FMSI 06471