Document VEdLMzYg6yaVgzzaVxdoKkm4

National Place, Suite 911 1331 Pennsylvania Avenue, N.W. Washington, D.C. 20004 202-737-6330 Organization Resources Counselors, Inc. February 7, 1985 Memorandum To: From: Subject: ORC Asbestos Task Force Darrell K. Mattheis Letter from Dr. Arthur Langer, Associate Director, Environmental Sciences Laboratory, Mt. Sinai, to Dr. John A. Moore, EPA, Concerning the NRDC Petition for a Prohibition on the Use of Asbestos in Auto and Truck Brakes Thanks to John Marsh, I recently received a copy of a very interesting letter as described above. I think that Dr. Langer's opinion, as formulated in his letter to Dr. Moore, will be of interest to the members of this Task Force. Enclosed is a copy of the "Langer Letter". Enclosure UCC 004203 re.cE'V.^B fEB 1a 1985 T n. UNCOUt, w. Copits of two Utters from Dr. Arthur Linger, Associate Director, Environmental Sciences Laboratory, Mount Sinai Medical Center to Dr. John A. Moore, EPA Assistant Administrator, concerning the petition of the NRDC for a "Prohibition on Continued Use of Asbestos In Automobile Brakes" are enclosed. It Is Interesting that Dr. Linger considers the documentation In the petition to be "mindless and pure rubbish." More Importantly, however. It Is noteworthy that Dr. Linger recognizes the significant differences In risk produced by different fibre types and Industrial processes. This Is the first time I have seen a statement by a member of the Mt. Sinai group that such differences exist. I don't know whether It represents a consensus among the Mt. Sinai scientists; on the basis of a recent conversation with Dr. Sellkoff, I doubt It, but the letter might be useful In the 'fchrysottle defense" and In cases where Dr. Langer Is a witness. Sincerely, UCC 004204 4"h f > hn-\  rff> u--m wMr-Axxux ma n u i rui/aranes COments C file f (CUNT PTWaT . tVDTPJUr. (WTO . THE MOUNT SIN A! . EDJCAL CENTER ONE GUSTAVE L. LEVY \E YORK N Y I002P Mourn Sinai School of Medicine `The Mount Sinai Hospital > . u* * */ Environmental Science* Laboratory Camming* Botie Science* Building 10 Ea* 102 Street \ew York. Seu Yor* 1002" >212` 6S0-A172 . -: or :or Pesticides ..:ic To.\ j c Substances Environmental Protection Agency 637 East Tower - TS7S6 401 M Street, S.W. Wasnington, D.C. 20460 . Dear Jack: * I have just read the NRDC petition for a prohibition on continued use of asbestos in automobile brakes, sent to me by Steve Shapiro. The documents are mindless and pure rubbish. My major concern with the documents is that data are invoked to support their own argument taken from several of sty own papers. Do you really have to answer this petition? c; r.c crel v, AML:jm cc: Dr. Steven Shapiro , ' k r l* * 1 , . . ' ' ' I. r.it.rv UCC 004205 r * * 'T t w THE MOUNT SINAI MEDICAL CENTER ONE GUSTAVE L LEVY PUCE NE'fc YORK, N Y 10039 Mount Sinai School of Medicine The Mount Sinai Hospital December 7, 1984 geviiWMcnte? SctMcet Laboratory . _ Cimuip 8ie trimcti Building John A. Moore DVM `U U 1 V 10 Ami 103 Straet Now York, Now York 10039 Aas latent Administrator for Pesticides f)fr tC *vgp*5<XJ7i nd Toxic Substance* - 1 <904 Knvlronaental Protection Ageney rue.. ^ ._, J7 b.t Tower - TS768 J t <a Mtw. tuman..,, 401 M Street, S.V. fa Kartasa; foxic SoCwanc Vaahlngton, D.C. 20460 Dear Dr. Mooret It has been made known to me that ay written reaarks of October 11, 1984 concerning the Batural Kesources Defense Council's Petition for a "Prohibition on Continued Use of Asbestos in Autonoblle Brakes" will enter, with other docuaentatlon. Into the rule-making docket along with the original petition. I am therefore requesting that this letter be substituted as a fonsal critique. My concerns regarding the petition are many, essentially focusing on lack of Insight and on an unscholarly approach to the problem ~ The B1DC clalas that both epidemiological and pathological reports "have shewn only recently that asbestos Is one of the largest single causes of environmental human eancer In the United States." This statement does not accurately reflect the literature. In support of this statement the petition cites BBS Secretary Califano who reported that approximately 171 of American cancer deaths over the next several decades will be "linked" to a'shestoe. There are approxiautely five hundred thousand cancer deaths per year In the United States which would roughly translate Into 85,000 cancer deaths per year "linked to asbestos." Xosedlately following this statement Is an attribution to Bieholson and co-workers who have estimated that eancer deaths in the United States from asbestos will number some 8,500 to 10,000 per year over the next 20 years. The authors of this document fail to reconcile this order of magni tude difference In these figures; fall to resolve the proportion of excess cancers attributable to workplace exposures; have not considered that If 8,500 cancer deaths will occur among 10-15 million "exposed" workers in different occupational settings, 85 thousand asbestos "linked" deaths means that everyone In the general population Is at the same level of risk. It seems farfetched; - Ij their discussion of mesothelioma and lung cancer, the BBDC authors use data from studies of Insulation workers In their descrip- \ UCC 004206 2876 *John A. Moore, DVH 2. Dtenber 7, 1984 tlon of Increased risk of osbsstos diseases in exposed populations. The nature of the fiber exposure, fiber type, fiber dimensionality end fiber eonceotretloo ere significantly different when compared to workers maintaining end repairing brake pads. Date for insula* tion workers say have little bearing for brake workers. These *r* vBcritlcally accepted as data applicable for all workers ~exposed to any variety of asbestos fibert * The assertion that all asbestos fiber types are carcinogenic in humans Is correct, Bovever, not all fiber types produce hunan mesothelioma (no wesotheIlonas have been reported aaongst huaans exposed to anthophyllite fiber in the workplace) and not all of the asbestos fiber types produce the sane attack rates for broncho* genic carclnona. While it la true that the three major varieties of asbestos used in the United States Induce both types of malignant tumors in experimental animals, industrial manipulation may alter outcome} * There is an attribution to a study conducted by my colleagues here in the Xnvlronmental Sciences Laboratory which revealed excess cancer mortality "in workers with short*term exposure-one month or less of employment in an asbestos plant." This citation appears at the end of a paragraph which states that "People living in the area of asbestos mines, mills, factories and even shipyards and family members of asbestos workers have become victims of mesothelioma despite what we would be considered light exposure to the dust.1* The asbestos plant in Paterson, dev Jersey is believed by many (including Seidman of the American Cancer Society) to have bad workplace exposures approaching lOOf/ml. Vlcholson occa sionally uses a figure of 35, I have used a figure of 50 but It is generally conceded the exposure levels were very high Indeed. One month's exposure during the second World War translates into a 500*1,OOOf/ml exposure day (10*hour shifts during the second World War). Using a 20-day work month this computes to a 10,00020,OOOf/ml exposure month. This would correspond to approximately a 2-5 year exposure In the occupational setting at the present 2f/ml level. Vo one would consider this a "trivial" exposure. Vo one would consider this a ^bystander" or "environmental" exposure; - In the very next paragraph, on page 6 of the petition, the work of Barries, carried out In the Devonport shipyards of Great Britain, is used to support their argument that mesothelioma may occur from "bystander" exposures. Barries and colleagues shoved that the tearing out of asbestos fiber on shipboard results in aerosols which may approach l,000f/ml in the immediate environment! Fiber measurements made during tear-out operations, aboard ship, have shown tens of f/ml of air in areas removed from the actual site of rip-out. Again, this is included to support the argument of the petitioners that "indirect occupational exposure" was sufficient to produce mesothelioma many years later. These indirect measurments are considerably greater than those encountered in most workplaces today. Additionally, the fh*r types encountered in UCC 004207 John A. Moor*, DVM 3 December 7, 1964 the Paterson insulation plant was woiitt and the fiber encountered by Barries In the Davenport shipyard was predominantly crocldolitt. the mesothelioma frequency for both these fiber type* exceed* those reported for ehrysotila In every study the world over. Vs are dealing with mesotheliomarisk for different fiber type*. Although ehrysotile asbestos does produce human mesothelioma one cannot use the experience -of workers exposed to croeidollte and amoslte as a "measure of risk for ehrysotile exposure;" " Although asbestos fiber released from automobile brakes may Increase the asbestos levels encountered la urban air the report of a mesothe lioma In a toll collector Is not evidence of an etloloxlcal associa tion! * I will support the contention of the petitioners that there are operations encountered during brake maintenance and repair which release "dangerous levels of asbestos during brake servicing;" - The general case for risk to uou-oecupatlonally exposed persons is based on risk assessment models. For example, Blcbolson <1983) ha* provided the Environmental Protection Agency with a document entitled "Asbestos Bealth Sffects Update." Using this model a general scenario is generated for both long cancer and mesothelioma and extrapolations are made concerning risk to populations for which no exposure data exist. Eleven studies provide lung cancer date whereas four studies provide the mesothelioma data base. The lung cancer studies provide fractional increases of lung cancer risk per unit of exposure but these fractional risks vary consider ably depending on fiber type and industry, go it is with the mesothelioma data set Which is based on a number of fiber types Integrated to yield a single r.lsk model. The question to be raised is whether data for croeidollte, amoslte and mixed fiber types (the Insulation worker data) may be used for ehrysotile. This, coupled with the relatively poor workplace fiber measurements, yields e model which mey be used only in its broadest context. These shortcomings were raised In a recent BBC document (1964) where ranges of risk were provided rather than a single value. Again, the mesothelioma date fl stress mesothelioma because segments of the population will live long and this will be the Important disease on the basis of time) is based on Insulation workers (mixed fiber), ehrysotile textiles, amoslte insulation, and asbestos cement product manufacture. The lowest values exist for ehrysotile exposure in textile plants. Therefore, all of the asbestos deaths projected Into the fhture are based on risk assessment for mixed fibers In a range of circumstances. The variance associated with these projections are large. The numbers of deaths attributable to asbestos brake pad maintenance amounts to some 500 per year over the next several decades. This value may be lover or even greater then given. We simply do not know; - The only pleural mesothelioma described in e brake repair worker, in which only ehrysotile asbestos fiber was observed In the pulmon- UCC 004208 John A. Moor*, BVM 4. December 7, 1984 ary tiifuu, was reported by vyulf. I b*ll*v* this working popula tion to k* at risk but I also believe this risk to b* lass than encountered with othor fibar typas in othar work envlroumentaj - Vbar* aro tha data to show that anbstitnta friction product materials ara "safe"? Vhat happens to e.g., aranid fiber whan sheared from a brake surface?i " III - Mhy is "sintered ^etal" compositions considered safe? Sintered hard natal netariaIs are now lnplicated in pulmonary disease (hard- natal disease). * I agree with the petitioners that there are many Instances where brake maintenance and repair subjects workers to asbestos fiber exposure which increases their neoplastic risk. There is no question that this occurs and that the risk is measurable. X similarly believe that there are no data to support that such risk exists for the general population. Exposure to the general population may oeeur and that the control of asbestos emissions should be Instituted. However, we have no data to support the contention that it represent* a "public health hasard." X believe it would be prudent to prevent such exposures from occurring to the general population even though there are no data to support that such exposures are hasardous. The federal courts have noted that one may rely on "general data" In making certain decisions. Therefore, If this petition is to be considered as a "general approach" to the asbestos problem then, presumably, the Environmental Protection Agency will base its decision on courtroom lav. As it now stands, one can only appeal for the decision to be based on the concept of "prudence" rather than science. The decision .should be made on the social basis and not a pseudo-sclentlflc one. nils Issue is a very important one and should not be approached In an upseholarly fashion, My strongest objections focus on the misuse of data and the uncritical use of these data in supporting certain contentions. Xt is a form of quasi science which we, as environmental scientists, cannot afford or allow fo go unchallenged as it reflects upon all of us and our work. AMLijm Associate Director, Environmental Sciences Laboratory UCC 004209