Document V3jZzyXgNRk3z5Yx9QjgzRrmj

REICHHOLD CHEMICALS, INC. .GreabWe. Chamisbry , 'Ijov/rJZcvrbnajrJ/rvJlrtyress KCI lUflDINO, WHITS HAIHS, N. T, 106 03 October 1, 1976 adores* rerly to rtelCHHOLO CHEMICALS, INC, MIDDLESEX AVENUE CARTERET, NEW JERSEY 07001 THONE <I) Gentlemen? At the University of Wisconsin at the Madison, Wisconsin Thermose.t Conference which was held September 23 and 24, one of our spokesmen commented briefly on the Occupational Safety and Health Act work place regulation concerning asbestos as it related to the molders of asbestos filled phenolic molding compounds. During the discussion our spokesman commented that the prescribed limited for airborne concentrations of asbestos fibers was cur rently 5 fibers' per cubic centimeters o air as a time weighted average (TWA) . it was pointed out during the meeting that this was possibly in error and that the current limit was,.in fact, 2 fibers per cubic centimeters of air, effective July 1, 1976. We wish to confirm that, indeed, the current limit far airborne concentrations of free asbestos fibers is 2 fibers per cubic centimeters of air for an 8 hour time weighted average (TWA). Summarizing some of the other points which were made during the discussion, we wish to point out that with asbestos filled phenolic molding compounds in which the asbestos fibers are completely encapsulated by the phenolic resin, there is almost no possibility for the presence of free asbestos fibers. The handling and storage of such a molding compound in line with good standard industrial hygiene practices should not result in the release of any asbestos,fibers in excess of the 2 fibers limit. A 71 exhibit_5__ Deponent. IdPnte9 j^-Rptr/JiL! WWW.DEPOBOOK.COM BXRDH 00552 -2- During the use of asbestos filled.phenolic molding compounds there are two possibilities for releasing fibers? (1) during the transfer of the compound from the bag into the feed hopper and (2) when subjecting the finished article made from the phenolic molding compound to a grinding, drilling or pulverizing procedure or to any other operation(s) which could possibly result in the formation of dust. Discussing point (2) first, Reichhold's past experi ence and the experience of some of its customers who have conducted air monitoring indicate that it is extremely unlikely that this type of operation would result in the freeing of asbestos fibers in excess of the 2 fibers limit. However, it is one area where extra caution should be taken. We urge that employee monitoring be conducted in these areas and analyzed for free asbestos fibers. , . Asbestos filled phenolic molding compounds, wherein _ the phenolic resin surrounds and encapsulates' the asbestos fibers such a3 the types supplied by Reichhold,- should not typically contain free asbestos fibers sufficient to cause airborne concentrations of asbestos fibers in excess of the 2 fibers limit. Wise business practice would indicate that the bag unloading area is another place" which should be moni tored in order to make certain that this is indeed the case. Our spokesman made a point during the discussion that the two chemicals used to opacify the membrane filter? namely, dimethyl phthalate and diethyl oxalate will liberate the bonded asbestos fibers in an uncured compound, thus, producing a falsely high count. The membrane filter test method, then, is not completely satisfactory in this instance. In summation,' once you have established, through a simple monitoring procedure, that you do not have airborne con centrations of asbestos fibers exceeding 2 fibers longer than 5 micrometers ,per cubic centimeters of air for an 8 hour time weighted average, you are not required to implement all of the . work practices, labeling, housekeeping, record keeping and medical examination requirements of the Occupational Safety and Health Act asbestos regulation. BIRDH 00553 3f We would also like to reiterate Reichhold's position as a secondary processor of asbestos fillers in supplying asbestos filled phenolic molding compounds,. Because Reichhold is able to meet the 2 fibers limit, we will continue to supply' either asbestos-filled or asbestos-free heat resistant" compounds. We will not inIti~ate^any~Jre(iuction of currently available prod ucts based on their asbestos content^ we..feel that molders, as a tertiary processor of asbestos will not be unreasonably affected by the new limit, and we will continue to develop and market products for their expressed needs. We appreciated' the opportunity to participate in this ' conference and welcome your individual'-inquiries on the subject. ( BIRDH 00554