Document YjDk3k3Q42xJ2mbgOL86ON4KO

utO-onl a.'' KrAUTY. SFFcCIS OF ASBESTOS* Dr.. Irving Selikoff curtenlly is Professor of Medicine ar.l Director of the Er.viror.njantal Laboratory ~t th; Moor.:: Sinai School of Medicine in New York, and one of the world's foremost erperts on the health effects of asbestos fibers. It can be concluded fro;.1, the tuitlmony cf Dr, Selikoff that: 1) Exposure to asbestos fibers can end does prn'-uce significant and detrimental changes in the human body. 2) Although the heavier the exposure the more likelihood there is of contracting asbestoses, even bow level exposure to asbestos fibers can ana does produce det-imental changes ii. the Inn.an body. 3) There is no known safe limit of exposure, below whies it c- a be said t:r t nc detriment tc the body will result. 4) The detrimental changer produced by exposure to asbestos will not be manifested in s detectable way until 20 to 30 years after the initial exposure. Whether the fibers are classified as cctrr-.arc.ial asbestos or not is really Dt important. Asbestos is a generic term for a number of hydrated silicates fJbfit, when crushed or processed, separate into flexible fibers made up of fibrils. & harpintiru mineral, cfcrysotils an,5 the naphibo3.es, asosite, crocidolite, are u**d coiHBercially as asbestos. Actinclica, tretaoiite and anthopbyllite have additional commercial uses. Exposure to each of the minerals listed above car, produce cancer In man. The cancers appear in various areas of the body, in cluding the larynx, lung, pleura, peritoneum and gastro-intestinal tract. In 1971, the National Academy of Sciences Cccmittee on Biological Effects of Atmospheric Pollutants convened a distinguished panel to address the health problems associated with asbestos. - kfrer due deliberation, the panel published a report that reached the conclusion that no type of asbestos can be regarded as free from hazard. The evidence in this case clearly indicates that the ingestion of amphibole or asbestos fibers creates a hazard to human, health. Furthermore, cnee fibers are ingested they leave the ability to pass through membranes and find their way to various parts of the body. While many fibers ingested or Inhaled into the body may pass through the body systems and be expellee, obviously some remain in the body. Carcinogens such as asbestos are stored by the body; their effects are often cumulative and irreversible. *This selected material is taken verbatim fror the April 20, 1974 MEMORANDUM AND ORDER issued by the U.S. District Court, District of Minnesota. Fifth Division in the case of United Sts res of America, et al. VS Reserve Mining Company, et al. Words in parentheses are inserted to clarify context only. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY UCC 005042 BA'3RCf^tENTAL RESEARCH LABORATORY DULUTH, MINNESOTA Based on the record Id this case which reflects the top scientific and medical input in this area today, it cannot be said that the (asbestos) fibers less than five microns in length* are mere or less dangerous than the larger fibers. Although long fibers can be ingested, it is the shorter thinner fibers which penetrate most deeply in the lungs. It may well be that the shorter fibers actually are more carcinogenic than the longer fibers. Forty-five to fifty percent of asbestos workers die of cancer, whereas in the general population 15 to 20 percent die of cancer. Exposure to asbestos by simply living in the household of an asbestos worker has been associated directly with the disease. Mesothelioma (a fatal disease peculiar to asbestos exposure) in the Patterson, New Jersey (asbestos) plant was not limited to those occupationally exposed to amosite asbestos. The office manager died of mesothelioma as did the general manager. Likewise, an engineer and the chief engineer's daughter who used to handle asbestos products brought home by her father died of mesothelioma. Epidemiological studies in several countries have demonstrated an association between diseases and relatively light neighborhood and household exposure to asbestos. There aTe substantial differences in the considerations that might go into setting a standard for an occupational setting as opposed to a community setting. Contamination in the community exposes the health and unhealthy alike to the problems associated with asbestos contamination. The residents in the community lack the ability to make a choice about whether or not they wish to be exposed; they are a captive lot whose only alternative would be to move to another area in the state. Furthermore, they arc subjected to contamination 24 hours a day, every day of the year, and their exposure begins at birth. The levels of fibers in the Duluth water and that of other cities is such to give rise to the conclusion that, given the variabilities of measurement, the residents of these communities may ingest as many fibers as do asbestos workers. When appropriate comparisons are made it cannot be said that indus trial exposure found to cause gastrointestinal cancer is greater than the exposure of the people in Duluth. There is a significant concentration of asbestos-like fibers In the ambient air as a result of the Reserve operation and these numbers are comparable to those that were fc .md to >ave been associa :ed with disease In other environmen tal situations. * Although amphibole fibers as long as 20 microns have been observed in Duluth water samples, most are less than 5 microns long with many less than 1 micron long. Source: Cook, Philip M., Gary E. Glass and James H. Tucker, "Asbestlform Amphibole Minerals: Detection and Measurement of high Concentrations in Municipal Water Supplies." Science 165:853-855, 6 September 1974. UCC 005043 Reserve Mining Company discnarg-s la:g? amounts of v'D-ita aaphibole fibers into Lake Superior and into the air of Silver P..-.v ^afj_ . The particles when deposited into the water are dIf period through Lake. Supprior and info Wisconsin and Michigan. The currents i'.i ;he nke. which are largely influenced by the discharge, cirry cany cf the fr'oeis in a sontVwnstrrly di roc trior, toward Duluth and are found ir suostanflcl qv-'ntl ies In the Duluth crlnl^r 5 water. Many of these filers arc mr^'-o' yic.sTly a- chemically identic* . to nmesite asbestos and an even la";-..-* u .tber rr>. <=inii ir to cTostte asbe- os. Ib.pocur*- to these fibers car. prrduc=. is'. csrosir, ite: J'elhua a--t usnett of the iur.g, gastroin testinal tract ?..d ,L -yt x. Avail-.-.':.. o evidence Andicater that the. f:.-ers pose a (health) risk then ir.ger cr-d ,cs v.u i os rhea inhaled. At present the evert is faced wi; .1 a situ.-'tic a where a cc-rcnercial industry is daily exposing the ..-rands cf peep" i 'o substar t'al cuantii-ies of z nnovm human carcinogen. JVpi.- is is u laced vycr tie fare that the C'ctt 1 s t-jc dealing with a situation ir: wh.tt.i r. '-l-s_er.ee cu : i carter in oxpe-riven" cl cnirr It where the effect on numuns is laig-.ly c - ecu1 - - a. ibe. s identical cal stviiar to those emitted freu Reserve's plant hove be: n directly aeso'-i ated with .. laerkc:! increase in the incident' of cancer in hv.m..r.r . Next to Engntfite and quar.z, c' .'raingtonits-f. :untrite is generally the moci abundanc ninzrsl th-cjgLcnt the ire formation on the Test Merabi district- in which Reserve's neter Kitche.ll Pit Ir located, except, of course, v-.ere ether metamorphic silica' as hs"e already L-veloped. In many or rtf c, che upper slaty and chtv-ty, where Resarvo nines, c -antingtoni .c-grunerite cortsonly exceeds ;0% of the rock. Reterve knew as early ac -160 .hut the Deter Mitchell Pit or ta.lncd "asbestos". This particular materia.! was the - ,-r- arcial type asbestos. One of the issues in this c?s<- it vhet'.e- rr net the t-phibole ninerals mined in the Peter Mitch -.11 pit are identical to" or "similar to" tmosite as bestos. It must be noted that asbestos is 3 ccrmercia1 tern- that her no indepen dent mineralogical or gaologic.'il oi,;nificar.cv, A-fos.fte, too, is a trade name and a non-mineralopicil tens, for certain fibrous minerals in tha cunmingtonite- gruaerite range that have corsetci = '. -mportence. Amosite dees not indicate a specific mineral corap 'sifion; it a range of nir.erai compositions with a range in bulk chemistry. Scientists ft. - bo s-'d.c j-nve i --.irsd that cutavini--v.it*--. -grunerite and amosite have in most in* trace sLcilar morphology, cry s c ailograr ay and chemistry and are, therefore, irvli. tinguishable. It is suffici.-".it co say cnaf i - Reserve's tischarge into both the air and water there are fiber- within the cumriingtonitc -grunerit*. range of fibrous amphiboles and wi-hin this number there arc- fibres that have the identical mor phology, crystallography anc chemistry as ant i 1 .e aabeotos, a kr.o-wn human carcinogen. *This selectee material is token verba tic. from .he April 20, 1974 LEKORANDUK AND ORDER issued by the U.5. District Court, District of Kinr.asota, Fifth Division in the case cf Unites States of America, et ai . VS Reserve Mi-'-lng Company, e: p.I. Nordr in parentheses are insetted to clarify context only. -JJNITED STATr T ENVIRONMENTAL PROTECTION AGENCY UCC 005044 B.p/IP0M^NTAL R'StlvCH LABORATORY L-: I'TH# K'NNESOTA While there is a doac-respoase relationship associated with the adverse effects of asbestos exposure tna there may he a threshold exposure value below which no increese in cancer vculd be found, this exposure threshold is not now known. It has been clearly established in th's case that Re.serv. 's discharge creates a serious health hazard tc the people exposed tc ? t. The exact scope of this potential health hazard is impossible to accurately quantify at this time. Sig nificant increases in diseases associated rit); asbestos exposure do not develop until 15 to 20 years after the initial exposure lo the fibers. The state of the scientific and medical knowledge available in this area is in its early stages and there is insufficient knowledge upon which to base an opinion as the magnitude of the risks associated with this exposure. The fact that few fibers have been found in the tissue of certain deceased Duluth resi dents may indicate that the general contamination of the ccnmunity of Duluth has not yet reached alarming proportions. Unfcr cunai oj.y - the real answer to this problem will not be available until com? ten to twenty ears from this date when the health experience of those exposed to the fibers emitted from Reserve's plant is reviewed. Reserve dumps 67,000 tons cf tailings waste into Laxe Superior each day. To get some idea of the immense size of Reserve's operations and the lake discharge, it should be comparer with the total amount of solids which naturally enter all of Lake Superior from streams and shore erosion each day which is approximately 12,000 tens (plus or minus 6,ICQ tons) per day. Reserve's contri bution to the suspended solid ecneertretion in Lake Superior would be five to six times larger than the suspended solids entering tbs lake from all of its natural sources. Clearly, Reserve's discharge is tnr singularly more significant input of suspended solids Into Lake Superior. The evidence in the case indicates that the daily profit in the operation at Reserve is in the neighborhood of Sfl.OCT'.OO per doy. In other words, for every dollar Anaco and Republic (the owners ci Reserve) initially invested in Reserve, they get back ninety cents each year the plant remains in operation. The testimony adduced at the trial was tc. the effect that (with product im provement) 'Reserve, Republic and ,-vrrec ec-cv-d .-'ford at the very least a $180,000,000 to $2.0,000,010 capita, curie with rezsrnabiy associated operating costs without substantially changing their economic situation as to profitability, intra-industry position, interest coverage, bond rat mg, etc. The evidence is clear that Republic and Arnco art t'-'o e: the largest 'Corporations in this coun try. They are prosperous re.' an c wcul d remain prosperous even after the necessary alterations (in tailings cisrcsel) are mad: Dei enda-ts have tne economic abc er.g ir.ee r in* caosb:' litv tc carry out an onland disposal system that setisfier the heart., sue environmental considerations raised. In essence they na-- e decides to cortinue exposing thousands daily to a substantial health risk in order to maintain the current profitability of the present operation and delay the rapitsl outlay (with its eoncomujtant profit) needed to institute modifications. UCC 005045 ukJ-o/77 UNION CARBIDE CORPORATION Chemicals 4 Plastics Group - P2 39 Old Ridgebury Road, Danbury, CT 06817 March 17, 1987 R EC /Ved MAR 2 4 1987 Medical Dept. To: R. G. Rowe, M.D. Tech Center Location 511 Subject: Asbestos Medical Questionnaire In response to your letter dated March 5, 1987, the answer to your inquiry is as follows: (1) The OSHA Asbestos Standard mandates the use of the Initial and Periodic Questionnaires in their entirety. (2) The MRMS Asbestos Workers Health Survey Questionnaire will not suffice and its use will not enable compliance with the OSHA Asbestos Standard. I realize that the OSHA quesionnaires are more detailed than the MRMS version and I would suqqest that it be administered by a nurse or technician at the time of the examination to avoid misunderstanding of the questions and invalid answers. One of the biggest problems in determining standards based upon dose-response relationships and clinical assessment of dose-effects is the lack of sound clinical data. The use of a standardized questionnaire should help to improve the quality of this data and I urge you to do all you can to get employee cooperation in its completion. / HCL/tt 0981E H. C. Lewinsohn, M.D. UCC 005046 k