Document Z4DmaNk36RXv0kw0zvzqGkwKJ

REDACTED CC: J. R Gorcyca s. c Johnson W. P Ledet J. E Kennedy J. C Warren May 10, 1,982 FROM: J. M. KAYSER R. A. KELLER A. H. NICKOLAUS ASBESTOS WORK PRACTICES AMD TSCA SECTION 8(e) REPORTING Thank you for expressing your concern about asbestos removal wprk practices. Your specific concern was that more attention should be given to employees during the time that old asbestos insulation is being taken out of Ops. 2-4 and other locations because the dust poses an "immediate health risk" to whoever breathes it. Although asbestos does pose a definite health hazard for those who are- exposed to it in substantial concentrations over long periods of time, the risk seen^s to be small for very short single exposures at a relatively small concentration such as the one you experienced. However, all exposures should be avoided since there is a possibility that"they may be cumulative. Asbestos is so commonly used throughout the country that it is likely moist adults have had some exposure to it. The concentration you were exposed to may or may not have been over the OSHA 15 minute exposure limit of 10 fibres greater than 5 /im in length per cubic centimeter (or 283,000 fibers/ftJ), but we suspect that it was relatively small. ^ Yojir concern will definitely be considered as we do our annual review of the asbestos handling procedure (I/H #10). Although bur procedure does conform to recommended practices for asbestos removal, some improvements may be necessary to assure that persons who are near the removal job but not involved in it are adequately protected from accidental exposure. "SAFETY IS MY RESPONSIBILITY" DXJ 011675 DUP 0821260  w. 2- - 4 In regard to your memorandum concerning the reporting of the incident to the United States Environmental Protection Agency under Section 8(e) of the Toxic Substances Control Act, the Director o Du Pont's Haskell Laboratory, the Director of Du Pont's Medical Division and Du Pont's Environmental Legal Section were asked to review your memorandum. Becaiuse the adverse effects of asbestos are already well known to the Environmental Protection Agency and the pattern and level of asjbestos exposure does not constitute an emergency, they do not believe this is a reportable incident and therefore we do not plan to report it. Zn reporting thi% to us, you have satisfied your responsibility, under the law. Nevertheless, if you wish to report it directly to the Environmental Protection Agency, you may do so. | If you choose t do so, Du Pont will not take any adverse action against you. This is guaranteed by law. JMKs sgd DU 011676 'SAFETY IS MY RESPONSIBILITY' DUP 0821261