Document YDB5GbGmxqModpanRM7vM5pXN

#' PLAINTIFF'S EXHIBIT GF-1920 WF o. Mr. J. Oliviero -ZZV.:Zr- New York F-:x P. S. Bettoli s*. South Bound Brook E= FILE f '1 ACTION 'Is?'- -- - * -V DESTROY 7 Due December 14, 1979 cc: C. F. Bien - Wayne L. Blecher - Wayne L. J. Faneuf - NY W. Fassuliotis - Wayne Sr<**nr G. R. Ferment Whitehall S. V. Cantor - l-.'avne E?A PROPOSED RULE MAKING ON ISE OF ASBESTOS FIBERS I attended the special meeting called by the American Faper Institute to parti cipate in their review of what action should be taken by this organization in response to the EPA proposed rules on asbestos and glass fiber use. Attached is a list of those attending. The meeting was split into two sessions, glass fiber and asbestos, with some attending both. There appeared to be considerable concern about the statement that very low diameter fiber glass was an unacceptable alternate for asbestos (see proposed rule 60065, "Health Effects of Substitutes"). Johns-Manville and Owens Corning, as well as TIMA, were very upset, about this and TIMA's consultant, Clifford Scheckler, and OCF's John Vyverberg read us a rough draft that had been prepared for the TIMA response. The gist of their position is that studies of workers occupationally exposed to fibrous glass dust for up to 35 years have shown no evidence of pulmonary disease attributable to the glass fiber. Their second point was that the EPA does not have any legal authority to include a regulation against the use of any glass fiber as a part of a specific rule governing the use of asbestos. The two studies mentioned by EPA as their reason for questioning low diameter fiber were performed by a method that could not be related to occupational exposure, and the author specifically cautions against '* directly extrapolating his results to man. We were provided with a pamphlet, "Current Status of Health Aspects of Fibrous Glass and Other Man-Made Mineral Fiber," Medical Series Bulletin 20-79, Third Revision, Industrial Health Foundation, 5231 Centre Avenue, Pittsburgh, PA 15232. A copy of the abstract is attached. We also received copies of a pamphlet issued by TIMA, "Health Aspects of Fibrous Glass." TIMA currently has underway a $4 MM research program which is sponsoring studies at U. of Pittsburgh (statistics on workers), Los Alamos (animal studies) and BrookhavNational Labs (mechanism for glass fiber dissipation from the lung). OCF claims that glass fiber, unlike asbestos fiber, is dissipated from the lung regardless of size. At the present time, only J-M manufactures "microfiber," which is less chan 1.5 microns in diameter. I was surprised to learn that three or four of the paper companies represented were using this type fiber with cellulose to produce high quality filter papers. It was acknowledged that all gas attenuated glass or wool refractory fibers contain a small proportion of sub-micron diameter filaments. An epidemiological study of 15,000 employees GAF 11364  i r :rral wo,-'. -.3 si lb r **. w.: In progress. To date, '..ve rtr t c same as the general population, at-.criir.u to Tiie Consumer Products Safety Commission did not in.'.wL. any reference to gia'-s fiber in their comparable proposed regulation, it vc.- r-porred that C?A was aware of a letter sent to OSKA by N10SH that states is no evidence of a health hazard from glass or refractory fibers. T..is is one reason why the jic:, industry is so disturbed by the tPA's tactics to ;-vp1vt them in an asbestos regulation. As now written, the burden foils or. the fiber producer Co prove his product is a "safe" alternate, even t:cuch the E"A .an produce no evidence it is 'Hazardous ro >-an. it was rec..ended that the companies issue separate responses to the . 1 :-=s -r>s a-'-t-tos -.tiers. \ will be -ent informal ion to use for our individual n.tien if we j.siv- to rn-.e any. The meeting or. asbestos paper was fur less organ! red. The API does not have members that produce papers for the construction industry. Any group resp.r<e, therefore, will be limited to ; i-ntcr-udd gasketinc paper and specialty papers. It was pointed out tii.it two laige gasket paper r.unufact'.irers, "icolet and Armstrong, were not r.-pn.-erred. The API said they would contact them. API's main concern was how they should respond to a" letter received from the Research Triangle Institute which asks for considerable information concerning the production and use of asbestos (see attached). API questions that they could furnish the infor- it ion, even if it were submitted to them by the individual companies for compilation, because of the highly proprietary nature of the data. The number of producers participating is relatively small and competitors might be able to gain confidential in format ion e>en from the consolidated figures. It was decided to reconvert- on January 17 to establish whether any group response via API should be made. In the meantime, they will ask EPA how they will preserve confidentiality. It is apparent to all tii.it the companies should first be assured by EPA that the information submitred voluntarily will be treated as proprietary. It is believed, however, that this may n >t be entirely effetive because ocher government agencies can'acquire the data fi :ne EPA and their case could be open for inspection. Would you please advw- v if CAF wiould be willing to divulge to API any of the information requested by the Research Triangle Institute. PSB/cc ' Attachments (?% y) P. S. Bet toll GAF 11365 YORK city ESCE-3E?. 12, 1579 - 10:00 A.M. David Caxleton American Paper Institute 260 Madison Avenue ?;ew^ York, Nw York 10016 Mina Plaia Anarican Paper Institute 260 Madison Avenue Mew York, Mew York 10016 John Festa American Paper Institute 1619 Massachusetts Avenue, NW Washington, D. C. 20036 3ehjamiii.5uil3^in- ( Fr.J Crane & Corpany, Inc. _ , South and Main Streets'-^-1'' ' ; Dalton, MA 01226 Roland Bernier Dexter Corporation C. H. Dexter Division 1 Elm Street Windsor Locks, Ct. 06096 Counsel to A PJ Durmingrton, Bartholcw & Miller ., 161 -Best 42nd Street New York, New York 10017 M. G. Thomas Fiber Process P. 0. Box 1713 Qtestnut Hill Road Rochester, N. H. 03867 Philip "Bettrfli GAF 114 Canal Road South Bound Brock, N. J. 08880 Timothy C. Saylor Hanrnermill Papers Group P. O. Box 1440 Erie, Pa. 16533 Paul Walker Hollingsworth S Vose Company 112 Washington Street East Walpole, 02032 John H. Lcrnruist Johns-Mar/.-ilie Corporation 1025 Connecticut Avenue, :r.\ Suits 214 Washington, D. C. 20C36 Larry E. Carlson Latex Fiber Industries Beaver Falls, New York 13305 Robert F. Dressier ("/. Manning Paper Corpany P. O. Box 328 Troy, N. Y. 12181 ~' Sy Geliman NCASI 260 Madison Avenue New York, New York 10016 Ray Pfleger NCASI 260 Madison Avenue New York, New York 10016 John Vwerberg Ojens-Coming Fibarglas 717 5th Avenue New York, New York 10022 Frank L. Wardley Quin-T Corporation P. O. Box 308 Tilton, N. H. 03276 Douglas Meaker Riegel Products Corporation Delaware Avenue Milford, N. J. 08848 Clifford L. Sheckler TIMA Consultant 838 S. Drive Metedeconk Brick Town, N. J. 08723 GAF 11366 i.VT 7r t rue- f.:-'us g;t" - *iri..'.rli..-:-r >rc use for over :5 r.rt.e.pate: -r <:.i ev.:s '* an = -d ft-out glass .-.C crer mk r t,k ce mineral fiber. research work. ir :** he*.':! w: s-ot? of ;.'rs. A* e result they nave rv.-: tur.es reined 10 They are presently continuing wri; '.'t-t .-, hrietron studies have dr-:n.-..-e:ed no sericus chronic adverse i.ikJff v .'facts. over. v.:-.h m.sssive exposures to highly respirable glass finer* ever the r.c-ril l.fe span cf ire ar.ix.iis. Firu-sJ i- .";--;tc- .el :*;e;tirns and int-apieu-a! ir,jeet-ns of fine dimeter r>sr fit-eps ;-tc s-mels have ;duoed tur-sr ce.!!::m.ent by these arl.f.ctal -e-n*. f t :. ' of t*re i"'rF! e-ud-es. while 'kfiis'-ing suff.?;*nl !f.*-r. to f_-:h-r h. of ^h.-ovs -'.`.f. 'e.s.'fv with tc ivrf.i:S r.f r of .Vo f *-, i.'.wiid rot `e directly e''.r-;- iateo 10 .. v,ce the -.vile of r posure. or* ge. factors of inherent resistance end r.eny otter c,.-cu.-st*nces. p.-oh,;i; this :r-..'jfer. Hunan studies of fibrous gisss workers. occupationally exposed to fibrous glass dust for up to IS years, have shown r.o pattern of chronic pulmonary disease diagnoses!* bv x-ray er impaired pulmonary function, no increased incidence of pleural reactions, and no evidence of pieurel x.a!ignsr.eies attributable to fibrous g>ss exposure. The only demonstrated biologic effects in man are these of t-at.siiory mechanical irritation of the skin and, infrequently, of upper respiratory tract irritation. AU of the r.ethea! research reported to date, has Indicated no significant chronic health effects in mar. as a result of exposure to fibrous glass. Environmental studies of worker exposures have shewn that airborne fibrous giess concentrations in ordinary fibrous glass manufacturing end fabrication operations are minimal. Environments] studies carried out in fabricetion operations, utilizing the highly specialized, extremely fine fibrous glass which constitutes less than 1% of all fibrous glass production, have- evidenced higher airborne concentrations of glass fibers than found in ordinary fibrous glass operations described above. GAF 11367