Document XODL5xKOk0EKkwd8d2pmoXo7J
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 -
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.
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ce Sard
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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