Document XR2RJREjbmEXnDO4wZqZZbY74

we* 'J wr* j. rrrjot f *to j* ava v ,oer* t.trAMT . <rnoi<P *Ifv<Ur r Is.CirCv'IIMOI 'TfHMf* T VW U, JO*Cf< **TTCtt MUVaftO M6LNAVCP c v et*atAw.**oM* AW.gii eat^c*"* a Mivtttt BOCOIA* . C*0 TUYID E VEQRO* A. etnY a. r j*toeh T.otofnicr tte*&* L'ce B.eeof'itr aice D.oBvno LAW OrKJCES Fxtzgbraid. Brown*. Leahy. Me Giu. & Strom .J rli36r. ' 1000 wooo'trv VA^cec ifl **iirMea ceteea *uy.? c m.34-9tnLjji. ** ***** * .^w., OMAHA. SE. feftJOa ' * >V^W^, November 8, 1972 Mr. J. s. Rpyer Young S&1&4 Corporation 1054 Central Industrial Drive St. Lotiis, Missouri 63110 D^r Spences Enclosed herewith is form of request for deferment of the monitor ing and medical examination requirements to December 31, 1973. If this meets with your approval, please sign the certification and return to me immediately and I will file it with the Secretary of Labor, if either you, Dick or Don have suggestions, please tele phone them to me and X will incorporate them in the request. X expect to add the letters referred to as Exhibit "B* upon receipt thereof from Dick Stapleton. I have talked to Dr. Van Atta, who referred me to the solicitor, Mr. Ben Mintz, who had me talk to Mr. Housh, one of the lawyers in the solicitor*s office. Mr. Housh stated that he would have the proper person with whom we should confer call me, but I have not received this call as of this time. I believe that we should '-personally present this request to the proper official in Washington and I should have his name by the time you return the request to me. "I will keep you advised. Very truly yours, JAMES W. a BROWN for the firm jWRB:itO' Enclosures cc: Mr. R. A. Stapleton yMr. Donald Bradshaw S -HAimim* *10 QCHl&f kuMOkJ) 01 117 1137 VM01155 w :l / l ftiir. U#e* **ai li*T " 9ct<U* 1. tM*. U ZMUagfl * Ut il i, ii^mo / ` MO OCCUPATIONAL SAFETY & HEALTH REPORTER E*fy Action Steiger end Congressman Cari 0- Perkins (0-Ky) chairBan of the House Committee oa Education and Labor, bad promised early acttoo on the Steiger amendment while voicing opposition to the amendment to the appro* prialtem b2) for the Pepartments of Labor and Health, Education, and Welfare exempting firm* with 15 or fewer employees from OSHA enforcement (Current Report, September 21, p, 411). House-Senate conferees later reduced that suxohw to Lhttt. Lefltoetlw Aetton Steiger's amendment to OSHA was passed in the Senate aa an amendment introduced by Senator Jacob Javiis (R-NY) to a public wwk& bill (HR IWJ V). On the House Ade, the bl& was reported out by the Committee on Education and Labor but never reached floor action. Congressman John A. Biatnft (D-MirmX chairman of the House Committee oa Public Works, deleted the amendment from the public works bill approved by the Senate because the measure was cooUoverskJ and subject to a point of order, Stefger's office attempted to have the bfl! brought to (ha House Root wtotr a suspension of the roles. This Kempt failed because only emergency and procedural bflb were given suspension action. Steiger's office reports that the bi-partisan commit* Bents to the bill still stand and that favorable action on the amendment is hoped for next year through regular channels, passage of the amendment was adversely affected by opposition brought by the Chamber of Com merce, the National Association of Manufacturers, and the United Steelworkers of America. Steiger claimed support for his amendment from the Hattonal Federation of Independent Busnesses, the Na tional Safety Council, the Nixoo Administration, the Nation! Small Business Association, and the AF1>CI0. Unto* Opposition Sieldon Samuels, director of Health, Safety, and En vironmental Affairs, Industrial Union Department, AFLCfO, id both the Steiger bill and the lavits amendment vea opposed by the IUD, the Steelworkers, the Interaittoru! Association of Machinists, the Oil, Chemical, and Arcmlc Workers, and the United Auto Workers. Though the national organization of the AFL-CIO supported the amendment. individual onion organization* ere divided on the issue. Standards OSHA PUBLISHES 'Til*AN" PACKAGE OF STANDARDS AMENDMENTS REVISIONS Amendments and revisions in the general industry job aafety and health standards n Part 1910 were issued m a clean- package by the Occupations' Safety and Health Administration on October IS. The revised standard* package as ivsued by OSHA wilt appear in a future supplement to (he OSUR Reference Fde. The purpose of tht tsvistoa is "to publish fo&y in one place the present occupational aafety and health standards contained therein in order to reflect many change* made during die current year and thereby to improve their usefulness and facilitate their enforcement; and to correct a number of typographical and clerical errors in the text of the standards; and to publish indexes with the stand ards, which are intended to permit quicker access to pertinent standards. "Ssric* ftfe revision does not make any substantive changes in the standards, it b not necessary to provide notice of proposed rulemaking, opportunity for public participation therein, nor any delay a effective date. For die same reason, good cause b found for not following toe regular procedure for rulemaking provided in S VS.C. 553 and for making this revision effective immediately." This revision includes amendments through September 22, 1972. General Policy AMERICAN SMELTING OFFICIAL CRITICIZES OSHA VIEW OF THRESHOLD LIMIT VALUES PITTSBURGH. Pa. - (By an OSHR staff correspond ent) - In some work situations, air monitoring or other kinds of environmental monitoring may give only crude assay of relative health ride, 'Cenneth W. Nelson, di.eelor, Department cf Environmental Sciences, American Smelttog and Refining Company, Salt Lake City, told the Industrial Health Foundation on October 1J. In some instances biological monitoring by means of blood, urine, or breath sample* may be far more accurate in measuring effective exposures as opposed to apparent exposures and may. in i'diticn, reveal intake of a toxic substance that might otherwise hare escaped notice. Nel son said. Lead h an example of a substance monitored better by analyses of blood and/or urine than by analyses of airborne dust and fume, he said. In the case of lead, compliance with biologic standards might writ be accepted as proof of compliance with environmental standard*. Threshold limit values have many pitfalls, Nelson said. In many instances TLV's ark concerned with comfort and have little direct relation to safely and health. In a few instances tlv's are eeiling levels that should nor be exceeded. Nelson said. The TLV's are needed by en gineer* and other, to help guide in the establishment of COMtC&V The Labor Department has taken the position that exceeding a 7LV is justification for (he issuance of a citation. The levels of airborne contaminant* should be assessed along with olher pertneni factors. Exceeding a TLV could be used for the basis fot a piovisional citation, pending review of other factors. In many Industries the only way to comply with TLV limits is To shut down completely. Nelson said. The Occupation^ Safety and Health Adnunistration should recognize the reality of the situation and modify its Standard* and procedures accordingly. Occupy,>**,**t Sofoij & Rt>ai<r 01- 117 1149 EXHIBIT "C" ) ; f u ) yOQ m*1 *11 " ^*So*i * Oetr 1*. IMt, 1 >>* <r. *-- t l, I'-UK' CURRENT REPORT 641 s } *" Labor Oepanm*** Dr. Floyd Van Alto* special assistant, OSHA Office of Compliance, said the Labor Department docs not have excessive dependence on TLV's. The asbestos standard involves IrioTo&cH iwmtlotfng among ottar thing;, he said. OSHA win include biological monitoring in standards where it is appropriate. Van Ata said. Air Standards Or. H. . Stringer, chief, Toxicology Branch, Division of Laboratories and Criteria Development, National In* stitufe for Occupational Safely and Health, said industrial (ir standards allow for excursions because they do not represent a fine line between safe and dangerous. The passage of OSHA reaffirmed at the federal level IndusIrial air limits that had been official standards for about 8 decade under die Walsh-Meafcy Act, but which as promulgated by die TLV committee or the American National Standards Institute, tad always been unofficial, recommended guidelines, Stokmgc* said. Being mandatory entails impeetion for compliance and that entails a fine appreciation of the intent and scientific basis of the ait limits, if fair judgement U to be made in appraising compliance. The dcterminalion of compliance under die terms of tone weighted averages, limiting ceiling and peak values and mixed temperatures h extremely difficult, Srotingcr laid. With a general lack of continuously recording air sampling devices, knowledge of frequency of peak values with safety and work habits, grab samples offer a ehalkngeablc basis for compliance determination, particularly ncognlxmg the safety factors in air limits. * Biological monitoring Is the main hope for improve* ment, Stokinger said. Safety Programs Dr. E. M. Dixon, medical director, Celanese Corpora tion, New York, said that fully automated new plant installations could have the same potential for hazards as dder places. Passage of OSHA changed the name of the game from "thou should** to "thou shah,** Dixon said. Although Blast companies hate maintained generally good and healthy workplaces, new official standards require a signi ficant expansion in scope. In the area of health, *h includes (l) tocav:d monitories and surveillance of workplace hazard*. (2) increased control measures to meet new lower limits for expuvote, <3) more extensive medical coverage, (4) additional recordkeeping. ($> substantially increased toxicity testmg and maintenance of toxicity data, (6) Use need to sustain relationships with related professional associations, and (7) concomitant increase in health costs. Industrial Nurses P. Jean Klara. Research Drpjftment Nurse. Koppers Company, Inc., said OSHA requite! an ext-.T.ion of the industry nur;.*'s ro!c. The trad-signal role n no longer sufficient. Some new areas of responsibility Include knowledge -of tiie woik environment and the toxic substances which ttuy be prewut. The tiwtit must learn v.cw screening techniques fee possible oeoapabofta! xpmn* and be come familiar with the criteria tnd standards set by the Nattonal Institute for Occupational Safety and Health. The nurse's ability to set as liaison between manage* menI and employee will be important in establishing a sound basis of mutual understanding of the new rules and regulations brou^it about by the Act, Klara said. The nurse w21 have to move from her sometimes isolated environment into the plant and become an active member of the safety and health team- LtpaJ Implications William L, White, Jt., aHomey, United States Shrel Corporation, said lawyers have a place in the standards setting procedure. Lawyers could be very useful in han dling variance cases and disputes that arise when con* census standards arc enforced as mandatory. An industry should mainlain close coordination of all OSHA activity. White said Individual plants should no: function independently, it wou'd be illogical to have one plant of a firm contest a citation for an alleged violation and another installation pay the penalty for (he same offense, Workmen's Compensation John E. Weekman, staff *upervsor, Workmen's Com pensation and Casually, United States Steel Corporation, said OSHA was meant to prevent industrial accident* and has no direct impact *n workmen's compciiwiion. Both the frequency an4 severity of industrial accidents and diseases are still going up. Weekman said, the only way to get OSHA across is to show the high cost of accidents and disease. Textile Industry F. Sadler Lov-. secretary treasurer, American Textile Manufacturers ins.itute, said the problem of bysiinosis is eot as great as was once feared. The Industrial Health Foundation studied some 20 plants and over 1,000 employees. But even after two yean of study some of the questions sre still unanswered, Love aid. The seventy of the disease and the number of people affected is known, but no one knows the cause of bysstnosis ot how to control It* It was found that some 5 percent of employees in larger plants had symptoms of bysstnosis, Love said. The industry feels a great urgency to solve the problem But the tftduwT) fills very pressed by the government stand ard for cotton dust uhen it is believed that a group of enzymes fay cause the disease, he said. Standards FmphasH Leo Teplow, Organization Resources Counselors. Inc., Washington, O.C., said the J972 injury rate would pro bably be worse than other years because of the undue emphash o standards to the exclusion of sht vofny and health factors. OSHA docs pur some stress on "good faith** bus it only affects the amount of the preposed pcno) tv and does not vliminatj the citation, Teplo* said. Yet *'good faith*' a at the hcatf of job safety and health. OSHA serves a useful purpose in elevating the im portance of safety and health in the company and brinoTig it to the attention of top executives, Tephuv CopnijKi S 1777 bj TKe Bu'*v f Ngiienst |c. 01 117 1150 Product* la f.f oor tool y oraor of ;uts**o pi *uv ed cordon ***. OctOtMr It, IJ. *# -'*nm v, k. ;rM. t i. ?>U3>e r- r <V 01 117 1138 jj fr JvC?t t*l llT M Ctft<0 9 etM*r it. !**. U ittliM 1,,,1. t i, -LliJO ffuunit** 4*..m.*ae*ot<<*Muur*, MCiBnMMtAiHKMn*at.faiLtAa.u.aauwcnaroa* mMae*eA*aca>ja.t. v*o'auo*wicunt>t>ia*v*a <LU*M f.HIKX&KJI. c ve*o* aeo<Mr a. alum* twpufl w.aswo Bfnsinm ntma%A.rt**r > r. arvei* min a*aeocca* it..amMobU*M*t uv omcKs TmazttAis>. Bkwk Leahy; McGiix & Strom teoo V008RC* TOU'EJI TtL. 44-MOO OMAHA. XZBX. MIOB .f.Bagn > caami nocs A.aaoou* w0'rn a. a. MM* M04>f9S4> November , 1972 Mr. James D. Hodgson Secretary of Labor Washington, D. c. , Si In res Attention: G. C. Gunther, Assistant Secretary of Labor Deferral of monitoring and jaedical examination requiremcnts of Standard for Exposure to Asbestos Dust Dear Sir: National Insulation Contractors Association, on behalf of the insulating contractors generally, respectfully requests a temporary variance from the monitoring and medical examination requirements of Title 29 Code of Federal Regulations, section 1910.93a. The variance requested is to defer the monitoring and medical examina tion requirements for insulation contractors until December 31, 1973. In support of this request, we submit the following: 1. Standard from which variance is sought. Variance is sought from the monitoring requirement contained in Title 29 Code of Federal Regulations, section 1910.93a(f), requiring monitoring ^within six months of the publication of that section and from the ^toedical examination requirement contained in section 1910.93a<j). 2. Variance sought. The variance sought is to defer the time for compliance with the monitoring and medical examination require ments to December 31, 1973. 3. Basis for request.M*VM**************M *************** **********M*MNNN^^^^M When the Standard for ExAposure to Asbestos Dust was issued, National Insulation Contractors Association recognized that the great bulk of insulation contractors could not, without assistance, comply with its requirements, especially the monitoring and medical examination programs. Host of these contractors are small business organizations without technical 01 117 1139 T f f \ 9t94*t*4 14 tint. aM<r ti T '*' JwM !>*.> lltlf C0t0ft **< {KtOMr t, )*, is 3--it4b . t si. luma - Page Two November , 1972 personnel to guide them or the knowledge of how to avail them selves of the needed technical assistance. Therefore, National Insulation Contractors Association appointed a special OSHA Task Force to facilitate compliance on a national basis. The special OSHA Task Force carefully reviewed the problems involved and concluded that the only practical way of enabling insulation contractors to comply with the monitoring and medical examination requirements was for National insulation Contractors Association (!) to identify or train persona who would be competent and available in all parts of the country to do the monitoring for the contractors, (2) to identify or train persons who would be qualified and available to make the examination of the filter Bandies and identify and count the asbestos fibers, (3) to identify and arrange for the availability in all parts of the country of medical personnel who are qualified to make the necessary medical examinations and properly take and interpret the necessary roentgenograms, and <4) to employ a technical director or directors who would establish, coordinate and supervise these programs, check the validity of the results, review the opinions of the different medical examiners and provide for the retention and availability of the records. Earnest and strenuous attempts have been made to establish such a national program. The special Task force has concluded, however, that certain conditions make it impossible to establish such a program within the required time limits and that by the time any such program could be established, the need therefor will no longer exist. A major change is taking place in the industry. All manufac turers of insulating materials are changing over to asbestos free materials. Attached hereto as Exhibit **A" are advertisements appearing in the November 1972 issue of the SICA Outlook, showing the availability of nonasbestos materials. Attached hereto as Exhibit "B*' are copies of letters from the major insulation manu facturers reflecting their programs to change over cmpletely to nonasbestos containing materials. The information we have received indicates that by the end of 1973 the contractors will be using asbestos free materials. Our investigation also reveals that the supply cf trained personnel who will be available, to the contracting industry to do 01 117 1140 * ) \ - Page Three November , 1972 the monitoring and analysis of the samples will be inadequate and that training programs will be necessary to make available trained personnel in all parts of the country. Because the need for these services will be eliminated before the training program can be completed, it is impossible to get trainees and, of course, with the elimination of asbestos from insulation materials, such a program would be pointless , Our investigation of existing monitoring and sample reading techniques indicates that opinions of trained personnel may vary as much as 300 per cent. This problem is reflected in the Bureau of National Affairs Report of the Industrial Health Foundation meeting at Pittsburgh, Pennsylvania, on October 11, 1972, copy of which is attached as Exhibit "C." With respect to the medical examinations, the officers of the International Union of Heat and Frost insulators and Asbestos Workers have advised that their members will not submit to the examination. Likewise, with the total elimination of asbestos from insulating materials within a year, such a program is impos sible to arrange and, even if it could be arranged, would serve a purpose only for a very limited period of time. In view of the foregoing, we believe that the monitoring and medical examination requirements should be deferred to December 31, 1973. We want to point out that the monitoring and medical examina tion requirements axe testing procedures rather than procedures to control the amount of airborne asbestos fibers. All of the control requirements of the standard would remain in effect. Consequently, this request for variance does not involve the elimination of any procedure required to control the amount of airborne asbestos fibers. With the elimination of asbestos from insulation materials, the asbestos problem will then be limited to instances of demolition and removal. The asbestos standard imposes very strict requirements with respect to such worh, including use of respirators designed to protect the employee even though the airborne asbestos fibers exceed 100 times the ceiling limits. 29 Federal Code of Regulations, section 1910,93a<b)(2)(iii) and <d>(2>(iii) . These occasions will 01 11? 1141 i A - Page Four November , 1972 be limited in number and some practical plan will have to be devised to meet monitoring and medical examination requirements in such situations. 4. Steps to protect employees. As pointed out above, this request for variance does not eliminate any action for the control of airborne asbestos fibers, it simply defers two testing techniques. Consequently, all of the requirements for controlling such fibers will remain in effect. 5. When compliance can be had. It is expected that by the end of 1973 all insulating materials will be free of asbestos. Consequently, the monitoring and medical examination requirements will be eliminated except in demolition and removal work. With the need for trained technicians thus greatly reduced, it is expected that compliance in these limited operations will be possible by the end of 1973. 6. Hotice to employees. On November , 1972, a copy of this request was mailed to Andrew T. Haas, General President of the International Association of Heat and Frost Insulators and Asbestos Workers, Rocro SOS Machinists Building, 1300 Connecticut Avenue, N.W., Washington, D. C. 20036. Such copy was sent by United States mail, postage prepaid, and by certified mail. In our transmittal letter, copy of which is attached, notice was given that employees may petition the Secretary of Labor for a hearing on this request. Respectfully submitted. ames W. R. Brown, Counsel istional Insulation Contractors Association CERTIFICATION R. S. Royer certifies that he is Chairman of the Special OSHA Task Force of National Insulation Contractors Association, that the information set out above was obtained by the special OSHA Task Force in connection with its attempts to set up a national 01 117 1142 - Page Five Bovember , 19?2 aystea for compliance by insulation contractors with the monitor ing and medical examination requirements of the Standard for Exposure to Asbestos Dust and that the statements contained in this request are true to the best of his knowledge and belief. <1. S. Royer, Chairman OSHA Task Force 01 117 1143 With SuperCaltempon thejob, Super Caltemp... Hie first asbestos-free calcium silicate insulation on the market. ,rM/c.eco >e*>A H you are thinking about rafcg asbestos-bearing isrelstioe material for process control or conservation of energy, you should know about the OSHA asbestos dust control regulations and protective measures required. 'Jhey'rc tough! You should aho know about Sup<r Caltemp by Pabco. The firsi arbtjtos-free high temperature calcium silicate insulation on (be market. OSHA Regulations In accordance with stringent new regulations of the Occupational Safety and Health Administration, you are responsible for monitoring nsbestes dual levels and maintaining rigid control of allowable concen tration. Where engineering methods of control are not feasible, you must provide protective respirators and train employees to use them. You are also required to provide periodic nedieal exams for any employee exposed to asbestos dust in excessof specified \miis. Recordsof personal and environmental monitoring must be kept for at least 20 years. Proxy grim prospect, isn't b? There is an alternative. And it costs no more. Other calcium silicate insulation manufacturers use asbestos fiber for reinforcement, PaV.o, makers of Super Caltemp, offers a specially reinforced superior product that is absolutely asbestos free. And that's not all Orty Super Caltemp offers these CRnt&erf advantages: 1. Shritfcg Steel Corrosion Protection. Austeotic steel equipment b widely eaed In petro-chemicai, pdtttem M/tofeg, power genera tion and related fields. Super Caltemp b an inhibited product which docs not cogtribute to stress corrosion crackieg of austenitic stainless steel. Z. 1200*F Use Temperature. 3, Patented"Precision Molded" Process assures uniform GL Other process calcium silicates are "cast" to half-round sections; the legs are then trimmed in an attempt co achieve a ertor futf-ctreomference pipe covering, Pabco's patented process yklds full round "pipes," which are then split in halt. Two half sections wifi match perfectly even if each section was made years apart assuring a uniform fit every time, with minimum time lost in trimming acd wiring. Super Caltemp b available in pipe covering, blocks, pro-formed elbows and cements. PabcoSoper Caltemp: A full line of ufcest-tiic industrial insulation, available now. For the name of your local independent Pabco Contractor/Distributor, write: PABCO industrial Products Division Ftbreboard Corp. P.O. Box saot Emeryville, Ca 94608 ni ii7 1144 17 **r i A Mifl jjf ed Mrdfii OetetMt }. lit*, la --' t #1, #5-L178 ImsoDflfflffiffliBS fimstoi asncer. These spun mineral wool insulations, all rated to at least 120G*F, cost less to install than calcium silicate products because they're lightweight and flexible, cut easier and fit better. There's no wasteful breakage. No delivery worries. And no asbestos problems. One-step Presfok Keene's Preslok metal' jacketed pipe insulation resists stock better than rooided ptoducts. Ato U'a convenient to install in one quick step. Helps suppress pipe noise. And Presiok ships flat, reducing storage space Oy two* thirds. Because Presfok accom modates pipe expansion, double layering is unnecessary. Available in true diameters of 6" to 24". i Curved Mono-Biock Meeting the demand for extra insuiatfon for larger pipes and boilers, high-performance (1900*F) Mono-Block is available in a new curved shape, in diameters from 24" to 60", There are fewer pieces to tnstaU. Ho hot spots because jomts tit tightty, KC 1200 Block This rigid insulation is your best bet for applications such as process equipment and breechings. Easier to cut than calcium silicate, it's easily impaled over pins or studs. KC 1200 requires less labor, eliminates breakage, assures tight joints, and is not dusty, For prices end details on any or all Keene industrial insulations, including selected calcium silicate products, write or cel! Keens Corporation, Ceiling & Insulation Division, U.S. Route *T, Princeton, N, J. 08540. Phone (609) 452-8800. Telex 843-475. TWX 510-635-2368 NOVEMBCR W? COKPOBA! I O N CEILING A INSULATION DIVISION We\*jus* begun to grout 01 117 1145 35 i i ii \ \ }i "T / 0 n Ij, fi.n vMtr ) era*) e*i u* iv4 U>tao* Mf, OfMf . IN*, is i*Mia* * KwJ-- t 41. 'uuo oI I Eagie-Picher has come up with a refreshing answer to your hot pipe problem. We call it Epiiherm 1200, a mineral fiber molded insulation. You'll call it the greatest pipe insulation ever designed. Were's why: t. No more asbestos bug>a>boo to worry about. Epitherm 1200 is asbestos-free. Absolutely X Epiiherm 1200 has a significantly tower "K" factor compared with other high temperature pipe insulations 3. Full 1200 service temperature. And no hedging. ,4 5,6,7,8,9, & 10. All the options you need .,, shatterproof, stable, noncorrosive. acoustical, incombustible. IPu 'pa D o/i n NOVfMeSfi 1972 easy to fabricate with hand-tools. Eplthemi 1200. The pipe insulation that has everything going for you. Call or write for the full story. Eagie-Piche- Industries, Inc. Fibers Department, 01172 900 American Bldg. Cincinnati. O 45202 )o D 01 117 1146 ti *1 iA * WMf ) *7 Pi iif a4 C0rn *{ eecai u, HI*, is j,m,m . 4. c 1. I'-tUil 0, Everyone In the industrial insulation business knows the many reasons for the use of asbestos-tree materials. And everyone in any business knowsthat having the handle on a widely demanded, labor-saving product Increases profitability. PAMROD puts you fnthat position with sbestos-free, molded high temperature "Elis" and 'Tees", because we're the only company that manufactures a complete line of such products. We have H all. What else we have Is the finest product available to the industry. Superior perform^., ance isengineered and built intoevery / ' PAMROO insulation product And. yet. t" PAMROO elbow and tee covers cost no ' than competitive products. fS?' Over the years, PAMROD has played an _ .. Important role in establish)ng manufacturing', standards for the insulation industry. Our, innovative approach to problem-solving. __ continues to result in improved Insulation* TM - materials and more efficient application ^ | techniques. V--' Since 1960, when users end suppliers of high temperature Insulation were Introduced to PAMROO's exclusive molded silica elbow end tee covers*, the entire insulation industry has been realizing substantial material and application savings through their use. So can you...today. PAMROD'sasbestos-free "CUs" and 'Tees" are available in sizes to fit virtually any Insulation need, and if you have a unique problem, we will help you solve It. too. For during more than two decades we have f excelled in developing specialty insulation for our industry. i> Give us a call. Let us prove to you that < Insulation products and services will mat you money. V\ >Mv>ultc<urd under U S.Ptitnt No 2.***.360 r' Sate*ottica: 2030 North Loop West. Houston. Tenas 77018. Phone <Tt3i 6S6-3775 NOVEMSEB 1972 01 117 1147 25 J u 01 117 1148 NICA OUUOOK i i