Document X8wpV1opqwrZ5E86YzoBznj74

PRIVILEGED AND CONFIDENTIAL September 17, 1984 PROPOSED AIA/NA POSITION ON FIBER TYPES_______ The revised PEL of 0.5 fibers/cc should apply in all settings, including both manufacture and construction. This PEL should also apply to all fiber types. As the record indicates, most asbestos used in the United States today and in the past was chrysotile. Crocidolite is, however, still employed in asbestos-cement pipe manufacture, where manufacturers have found its use crucial to their product, and is inevitably encountered in removal, demolition and alteration work, especially in ships and in industrial set tings where insulation installed in the past contained crocidolite. As discussed in Section II of this brief, at pp. ______, OSHA's reliance almost solely on epidemiology studies in which workers were exposed to considerable amounts of crocidolite biases its risk assessment to overestimate asbestos risk. At the same time, the difficulties of iden tifying all. working environments where crocidolite may exist and of distinguishing fiber types in routine monitoring make it impractical for OSHA to set a differential fiber type standard that will be practically enforceable. Beyond the impracticality of different fiber type standards in settings where more than one fiber type may exist, a PEL lower than 0.5 fibers/cc would not be techno logically feasible given existing constraints on both dust CAPCO JEN 0012110 control and monitoring. Moreover, given the low average exposures that will be achieved with a 0.5 fibers/cc stan dard and the accompanying ancillary provisions being pro posed by AIA/NA, a lower PEL for any fiber type is not necessary to eliminate significant risks in the workplace. OSHA should thus adopt a 0.5 fibers/cc PEL for all asbestos fiber types. CAPCO JEN 0012111 PRIVILEGED AND CONFIDENTIAL September 18, 1984 POSSIBLE AIA/NA POSITION ON FIBER TYPES SHORT FORMULATION OSHA should adopt a PEL of 0.5 .fibers/cc for all asbestos fiber types. The record does not provide suffi cient support for regulatory distinctions based upon fiber type; substantial difficulties would exist in enforcement for different PEL'S for different fiber types; standards lower than 0.5 fibers/cc are not technically feasible for any asbestos operations; and a 0.5 fibers/cc standard would eliminate significant risk in all workplaces. CAPCO JEN 0012112