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FILE NAME Manhattan RBM DATE 1972 DOC RBM025 DOCUMENT DESCRIPTION US Dept of Labor Public Hearings on the Standard for Exposure to Asbestos Dust of the U. S. DEPARTMENT OF LABOR Docket No. In the matter of SSTARMANDTARMAND PROFOL PROFOL PROFOL PROFOL FOR PATOSURE oy ff WWOOLLFF WOKING WOKING WWOKOINGKIWONKINGGWOKING TO ASBESTOS DUST COPY COPY Washington D.C. Place March 15 1972 { : Date 104 Pages 220 through HOOVER REPORTING COMPANY INC 1 Official Reporters 4 HN i Washington C. | 546-6666 - _ TE ~ won e . a ce Sard ; pL ET ns EXAMLER GOLDBERGGOLDBERG Mr. Weaver HR WEAVER oe, My name is Isaac H. Weaver I am * ; : : oan : ;f Director of Environmental Control for Raybestos- Corporate Director Manhattan IncorporateIdncorporated I have been engaged in this capacity for the past two years prior to which I was employed in various engineering and technical management capacities for .. approximately 25 years all but two of which were in the |i i oe employ of Raybestos eae Prior to my initial employment with Raybestos- Manhattan in 1946 the occupational hazard of asbestos dustCe, exposure had been recognized and extensiveextensive engineering con- i me s Oe trols had been implemented to reduce worker exposure and to ee et re wtas eg cope with the problem to the extent that was feasible with a ee then existingtechnology Scientists at Raybestos | i adopted positive optimum adopted progressive attitude toward a progressive positive ce degitee of control with the goal goal of achieving maximum feasible reduction of airborne dust concentrations concentrations . Much original engineering design and dust control development was accomplished at our M_ anheim Fennsylvania a andt Charleston South Carolina late 30's and early 40's asbestos Some of textile plants during the te mie this was in conjunction eet em as with various Government agencies as well the foremost foe Pet ee en industrial hygiene consultants of the time While much has been done to reduce exposure of e e aus employees to airborne asbestos fiber in our plants and in Wig 1 i much : | the plants of other many asbestos product manufacturers , remains to be done to further improve the situation However s et of ee investigation of the experiences our experiences in our enum others who have been wrestling with the problems of achieving aer i fiber concentration levels in asbestos ever more airborne regarding feasibility during processing operations doubt in my mind to grave the past several years has led the of conmoe i than 5 or 6 fibers per sistently attaining levels of less ete cubic centimeter in many critical operations To place this problem in proper perspective requires that one the accept workplace to environmentalenvironmetal improvement improvement undertaken with the precept goal of control approach= that an engineering in the normally is zero exposureexposure or zero dust have designed an engineering control mess emissions We never aan a 5 million particle per erte nt system with the idea of achieving woeneet cubic foot level Lo cubic foot level a 2 million particle per e LS cubic centimeter level Our goal always teWO or a fiber per Foevnnte and that always will remain pam has been to achieve zero exposure exposure ., 23 t the goal proceedings During recent concerning the setting to asbestos fiber I of standards for occupational exposure misinterpretations misnterpetaions misinterpretations of disturbed by apappaprentarent by wawasswaswas veryvery much control Fish asbestos standards and enforcement practices be disregard or lack of knowledge and what appears to technical Heading Heading Heading feasibility for attaininagttaining suchstasndards tandards 195 British medical governmental and industrial authorities have established an admirable goal of maintaining all asbestos operations below an airborne concentration of two fibers per cubic centimeter However is is my impression and belief as confirmed by Dr. Holmes this morning that te er oe they have many critical operations where this level is not en sophisticated c--le ns being maintained in spite of expensive and : tier came . sophisticated we eY environmental controls and strict work practices that they twengue have maintained maintained maintained maintained and e. improved + upon as rapidly as advances in feasibility .ome technical mes feasibility have permitted American mas -e I recommend that the a asbestos industry take full advantage of available British technology wherever possible to improve our occupational environmental control ae of asbestos hazards but I think it is equally important to give full consideration to British experience and knowledge concerning what they have found to be feasible regarding | standards and their enforcement We do not believe it is oe Memsfiner MP TSa oArREbTenmekE vor eRPEes speitad ewpetaerer ; ae ot eg Aa : i : it technically feasible to achieveachieve a level of two fibers per cubic centimeter in all ofour operations either now or it within the foreseeable future 5 ' With respect to the measurement of airborne asbestos i fitem ; fitem concentrations I seriously seriously seriously question the reliability reliability reliability of } : | i the nombrane filter the nombrane filter method particularly at levels below 5 : { ) : a At the present time there are very few technicians leeluee came ee 195 of tho who aretrained have the experience in this country and ability to perform the tedious andconsuming is an inherent requirement of the microscopic analysis that __ membrane filter experience with method Furthermore , Manhattan's this procedure even when using trained and confidence experienced confidence have not bolstered our confidence microcopists ws ; potential in the reliability reliability of the basic method While we and others often have deplored the oman filter monitoring method enaere shortcomings of the membrane many eo as he an to come back to the conclusion that while it {{ bs we always seem a 8 minesi ater i work with still it is the best 1 5 ' tool for anyone to ' i i is a poor : eSai\ T we have at the present time e In any event I remain extremely : : Li T'e i a ae ts t4ae i Tome ee of effective monitoring by i dubious regarding the feasibility j * enforcement personnel by means of F 4 industry or by Government ' the membrane filter method at its present stage of development Regarding of the medical and health :: Regarding question Regarding the t 13 13 hundreds problem we have reviewed hundhundreds reds of medical wet studies industrial hygiene hygiene ststudies udies relareltatinig ng Cobestos cientific cientific cientific cientific and industrial and and industrial industrial industrial hygiene tto o Cobestos cientific have retched their their control and have and retched the firm the firm control their saleh saleh emt o o shat shat no conconclusive clusiconclvusivee evidence evidence evidence exists exists on whictho which which which which need need need needneed fox foxfox a threshold which which bite length teighted microns poon greater poon poon we than 5 greater greater than 5 microns in length in - length tinc tinc on a teighted teighted ee especially image appears . image image babcisacis bacis . This This appears This to to be especially especially especially the the case case in great nagand nagand nagand to chrysotile chrysotile chrysotile chrysotile astestos astestos astestos astestos which which which accounts accounts accounts the f foror the great majority of both Industrial and environmental exposures 197 : i 7 : SLAY ORE i maintaining maintaining maintaining difficulty difficulty , difficulty impossibility The impossibility or of maintaining , | lower than 5 fibers per cubic reliable reliable controls at levels || centimeter with the lack of scientific fact to : centimeter coupled | i lower standard leaves me to recommend fo justify the need for a pornea) standard of eh! the adoption of the presently proposed permanent wemntes t 8 as determined by the membrane - nev 5 fibers per cubic centimeter i whatever improved monitoring method may we ! filter method or by cy tone wom be forthcoming oF e I believe this recommendation coincides with that Hygienists | Hygienists of Governmental Industrial | of the American Congress 10 and scientific |eam of eminently qualified medical t 1| and a number | to study , pnoenneir authorities who have devoted a great amount of effort AB t i yeh 12 _ 13 2| 3 H! : :: 3 | and evaluation of this subject I to testify regarding I appreciate this opportunity standards enthusiastically H the proposed asbestos and I endorse the concept of uniformly applied and enforced occupational if safely based on sound factual data safely and health standards i all available sources of pertinent input obtained through | that the timeframe within which Unferbunately I am convinced enthusiastically y : , 21: | i ; Hs i i ui the presently proposed standards criteria and recommendations inadequate to permit full and proper 4 were prepared was grossly and consideration of all available data by the parties analysis Mant a Ye in the decision Min i te 7 who participated 95 tee | informat time had been allowed for ate I feel sure that if more and scientific information | study and review of available medical +i | H 198 Department personnel by NICSH and the Department Labor standard | and fox more extensive deliberation deliberation by the Advisory Committee appropriate on Asbestos Dust fax mone extensive and criteria STS we recommendations and for recommendations would now be available as a basis aeemtons e temeny a safe fair and enforceable standard setting a That is the end of my remarks ramen cea MR MARSH Raybestos employs 6500 | people 80 of these are engaged in the manu- 3 Approximately of containing products facture and distribution including friction materials asbestos textiles packings and asbestos reinforced plastic wish on the emergency standard " I first to comment cubic centimeter established on December 7 i of 5 fibers per cubic t 1971 and the proposed standard for exposure to asbestos 1972 7 January in the Federal Register on 12 dust published has : | AC Mr. Teaver indicated we believe it is technically feasible to achieve the fiber level in most of our operations It It cannot cannot cannot cannotcannotcannot cannot , immediately however however however however however be be acomplished acomplished acomplished acomplishedacomplished acomplished acomplished accomplished , Up to two of millions of dollars will ars t ycans time and the expenditure . ycans Larwen pop amen ee Since the imposition of the emergency standards on a Sieg oe 5 have nen Sena December 7 we been studying all operations to determine |i aeny i aeons where inxediate compliance is possible and where engineering { Just control equipment or changes in equipment a - wo studies studies additional oman: standard | et to achieve the are necessary eo ee manufacturing procedures H } e i { { I i 4 +i It is now clear that in order to cocmply omply with the 199 standard certain produpctsroducts must be discontinued as | fiber t will | it not be economically feasible to produce them at least i | In addition to the discontinuance of certain the standard of 5 fibers and consequent loss of jobs products manufacturing costs Many a pez cc will result in higher and the industry F products produced by Raybestos Our vulnerable competition SP will be increasingly to foreign textile workers has already forced been forced to lay off tetxtilee xtile company has nner of additional lay- and we are concerned about the prospects off's and loss of business due to lower priced foreign imports According tofigures from the United States Depart- of acbestos textiles of the type ment of Commerce imports more than doubled between | manufactured by RaybesMtoasnhattan asbestos products of the 1969 and 1971 and imports of other type 50 increased nearly manufactured by Raybestos 4 Higher manufactured costs for United States manufacturers will surely | accelerate this trand andencourageencourage the flight of American capital and the loss of American jobs * On the subject of llaabbeelliinngg we believe cautionary in some lakel is appropriate that all Market requirement instances but feel that a finished products containing be labeled as proposed 5 or more percent by weight of asbestos iin n the Advisory Committee report is not warranted To our tena 200 ( been that knowledge no evidence has ca aetna at | Ai presented to indicate any harmful effect has resulted from the normal use of effect containing thousands of essential products ~~ ie The National Academy of Sciences in its report on thebiological effect of atmospheric polutants states Asbestos Asbestos has become almost indispensable in modern technology Nowhere is this fact more evident than in the area of safety Safetyproducts manufactured some materials produced by RaybesRtoas ybestos RaybestosManhattan range from the common theater fire curtain curtain to sophisticated heat barriers surround- ing the enginesengines of the Saturn boosters Thehoods coats trousers aprons and mmitio to that protect steesl teelworkers from the heat and splash of molten metal are made of asbestos cloth FirefightingFirefighting Firefighting and rescue teams are protected againast gainst Ancineration by specially constructed garments of asbestos B cloth Woven asbestos cloth and tape around hot piping aboardships or in industrial plants , protect operating personnel from harm Similar asbestos tapes guard electrical cables to prevent accidents The safe operation and control of the nation's industrial machinery machinery construction equipment agricultural implements and mining apparatus as well the millions of P g cars trucks and buces on our highways are dependent on the esboston composites that are used in the braking andppower ower v P transmission systems with which all of these present day 201 Becessities are equipped q Packings of astestos composites are used to scal countless dials that control all water gas and steam Mines in industrial manufacturing processes Gasketinogf Rebostos effectively seals internal combustion engines and These are just a few of the many uses to which stestes is put to protect life and property We believe the labeling provisions for finished roducts contained in the Advisory Committee's recommendations To unnecessary because of the absence of any health hazard | associated with their normal use Furthermore such labeling Is likely to encourage the use of substitute materials which By not have the superior performance characteristics of sbestos products and may be less safe To quote again from be statement of the National Academy of Sciences Asbestos * too important in our technology and economy for its scential use to be stopped the fibersfibers per cubic centimeter be imposed in twoyears As Weaver has indicated we do not possess the technical pledge to achieve this level at many critical operations prfore it is useless to speculate on the economic con- rences of the establishment of such a standard 202 a ied We understandthe dilemma in which OSHAis placed the impositionby law of an arbitraryarbitrary and altogether M9 short time span in which to develop enforceable standards willwill protect the employee and his job We sincerely that come way be found to provide adequate time to fully fully regulations sider the technical feasibility feasibility of the proposed regulations o B the opinions of expert and experienced medical and ot emeet . catific authorities who are not convinced that such Cente are Set xlations are justified on the basis of the available FO Rance Rance on It would indeed be a tragedy if restrictions were Need on the industry which are not needed to protect the 1th of the worker or the user of the products but which elimination result in the loss of jobs and the of thousands of asbestos containing products that protect ee a ate lives Thank tate lives Thank you cum ee MAZITHHER MAZITHHER MAZITHHER GGOLDOBERGLGODLDBERG BGOELDBERRG G May the gentleman be excused we 3 171. 171. LEONARD LEONARD LLEEOON NAARRDD LEONARD MMyy nanmame e is is JosepJohseph Leonard LeonardSafety * the wO2 of the International International International Longshoremen's Longshoremen's Longshoremn's Longshoremen's Association Association Association Association ar di other other other subcommittees subcommittees subcommittees subcommittees subcommittees of of occupational occupational oc upational occupational safety safety safety and C10 subchaimman subchaimman subchaimsmuanbchaimmansubchaimmansubchasiumbmcahnaimansubchaimman on on ocupational ocupational occupationaloccupatociupoatnionaall ocupational ocupaoticoncaulpational ocupatiocnaclupational ocupational safety safety sasfeatfy ety I member : I am a member ' Safety BS2 Intional Safety Conference on Labor Occupational , et Heater of the impartial committee of labor and occupa- AO Ee RERe tal safety which takes in over 10 million men On our ae te