Document XRGXE28q5Q5OMELv22zpmj16R

' * PLAINTIFF'S EXHIBIT CAP-1720 NATIONAL INSULATION MANUFACTURERS ASSOCIATION 441 LEXINGTON AVENUE NEW YORK, N. Y. 10017 ASDESTOS CEMENT PRODUCTS ASSOCIATION 521 FIFTH /'.VENUE, 20TH FLOOlf" NEl-7 YORK, N. Y. 10017 Ka'rch 5, 1971 PUBLIC i- ;aring statement CITY OF BOSTON AIR OLLUTION CONTROL COMMISSION PROPOSED REGot .TICKS NO. 5 i'.KD NO. 6 Oancler..en, I Cl if lore L. Sheeicler. I repre scat the National Insulation Manufacturers Association and Cha Asbestos Cer.ar.t Products Association. I serve as Chairman of the National Insulation Miar.ufacturers Associr.tion Health anti Safety Committee. Also, Chairman of the Asbestos Cement Products Association Health and Safety Council. Vie respectfully call your attention to the City o f Boston Air Pollution Control Commission.Proposed Regulation No. 5 "Esp ecially Hazardous Materials".. and Regulation No. 6 "Miscellaneous Dusts and Dus t-?roducing Activities". Both of the Associations that I represent, support the adoption of codes, rules and regulations dor-igned^to control exposures. i CAPCO JEN 0003391 It is essential to protect workers that spray, and other construction employee.*;, from exposure to potentially hazardous amounts of Asbestos or sry oti'cr dusts, during the course of their work. I'e also support efforts to reduce or control the emission of dust allowed to escape into the community atmosphere. ror.giy oppose, however, the complete banning of any useful o essential cal, j.nelecmg asoostos containing products, cn the unproven ics use ir.ny cons tzi tricc health hazard to the general public Via are compelled to voice misgivings cor.ecr acgulntron 5.1 m that 11 i.s the beginning of establishing an extremely < rout precedent. This P.eguiatitr. would bar. a materiel primarily essential to men ; safety and well-being. Many materials possess some of the properties of asoe ;tos - none combine them. all. It is this unique combination of properties makes asbestos indispensable to so many applications, There is evidence that where adequate control measures were instituted the t spraying of asbestos insulation could be controlled to the degree that only the normal, trivial amounts of asbestos were found in the ambient air. Eadiacion is a hazard but we do not ban x-rays - instead we control the hazard. Automobiles emit carbon monoxide but we do not ban automobiles - instead wo attemot to control the emissions. i" CAPCO JEN 0003392 -3- The opinion that asbestos can and should be controlled instead of banned is. shared by many of our leading medical scientists. I respectfully call the Committee's attention to comments by Dr. Lewis Crslloy, U. S. Department of Health, Education, and Welfare; Public Health Service, presented at the XVI International Congress on Occupational Health, Tokyo, September 1969; "Asbestos can be used safely in modern technology if adequate precautions are taken to prevent excessive and unsuspected exposures". In the October, 1969, Volume 10v,i'umoor 4, or tne Crticial ^ournaj or me American Thoracic Society, there is a paper entitled ".Asbestos and Health in 1969" bv Dr. George V.'. V.'riuht. Dr. Wright said: "The- relationship between asbestos and health of humans, as reviewable in 1969, indicates that serious exposures to asbestos fiber can occur in certain occupational and immediately adjacent environments. Fortunately, the con centration of asbestos fibers in these settings can be controlled. The environment of the insulation workers ( is more difficult to control than the more fixed and permanent environment of the factory and associated neighborhood. An approximation of the concentration of' respirable-sized asbestos fiber that can be tolerated without the risk of pulmonary fibrosis has been achieved. There is reason to believe that this concentration will ... (Con|'<'i. A : CAPCO JEN 0003393 also minimise the risk of pulmonary malignancy including mesothelioma. Because of the long time lapse associated with the development of malignancy, longer periods of observation are desirable for a final decision on this point. There is reason to believe that the occupational use of asbestos fiber can achieve the same degree of safety ,,* as the use of explosives, radiation, and beryllium, although extensive alterations may be required in the control of production, and manufacturing, the containment of asbestos fiber so that none escapes to the outside, and the proper disposal of solid wastes containing the fiber. The risk to the general public posed by the mostly intermittent exposure to the low concentrations of asbestos likely to be present in the ambient air has been exaggerated beyond the limits imposed by known facts. Research to develop the necessary additional information upon which appropriate and realistic measures for safe use of asbestos fiber can be taken should be the goal in the next few years." On February 26, 1971, Dr. Irving Selilccff appeared before the New York City Council Committee on Environmental Protection. Dr. Selilcoff told the Committee that he objects to the ban on asbestos sprayed insulation and voiced misgivings about the CAPCO JEN 0003394 5 precedent such a ban wight establish. Ke indicated this type of action could lead to the banning of other materials and I quote;"one substance after .another could be banned". Dr. Sc-likoff was asked the question by a member of the Committee, "Are adequate protective devices for the safe use of sprayed asbestos available today'?". Dr. Selikoff answered flatly, "Yes". Dr. Irving Sol more again reiterated these opinions beiore the Cnicago City * y' Council Committee on environmental Control on March 3, 1971. The nations] Insulation Manufacturers Association and the Asbestos Cement products .*.saociatton urge this committee to revise ;.cge_nticn 5 and G, Delete any reference to banning of asbestos or any other material. Establish Clifford L. Shackler, Chairman National Insulation Manufacturers Association Health and Safety Committee Asbestos Cemant Products Association *. Health and Safety Council CAPCO JEN 0003395