Document Raz23bLL231kYgoKKQoD55BXB
FILE NAME: Union Carbide (UC)
DATE: 1978 Aug 22
DOC#: UC055
DOCUMENT DESCRIPTION: Letter to John Marsh from Raybestos Manhattan AIA - The Most Important Points to be Included in an Industry Statement on Asbestos and Health Problems
D IV IS IO N
no
LO C A TIO N
TO: Mr. John H. Marsh
August 22, 1978
SUBJECT:
Asbestos International Association The Most Import Points to be Included in an Industry Statement on Asbestos and Health Problems
I have read Harry Rhodes' letter to you dated August 15, 1978 and note his concern about my attitude toward what triggers the medical surveillance of asbestos workers.
. I have also re-read the sections in the Excerpts from the Asbestos Industry
Response to OSHA dated April 9, 1976.
'
It is not my intention to insist upon unnecessary medical examinations, and I think that the'insertion of the word "occupationally" in the 3rd line of item 6.3 on page 2 between "employees" and "exposed", will considerably narrow the field.
I am certain that the trigger for medical examinations should be "occupational
exposure" and not over-exposure implied by limiting the surveillance to those
"persons regularly exposed to airborne asbestos fibers in excess of the prescribed
standards." The viewpoint expressed in the AIA document that it is unnecessary
to keep under surveillance persons exposed to asbestos below the prescribed
standard is not a valid one in the light of the acceptance by the industry that the
exact level for the prevention of cancer has not teen demonstrated. It is essential
to build up data on low levels of exposure and, therefore, all "occupationally
exposed" workers should be examined, re^rdless of fiber count. At the same time
every effort should be made to insure that adequate records are made and kept,
shewing the type of exposure, duration of exposure and intensity of exposure for
each individual to correlate with subsequent medical parameters analyzed. If the
asbestos industry wanted to make a positive contribution, the development of a
viable tec hiique for auditing the applicability of the provisions of the standard
to various jobs and operations would be of immense value to workers, industry
and regulatory agencies alike.
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Hilton C. Lewinsohn
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