Document Z8k3Nm8KDBRZ20Bx8zqgLGY3Z

' v ':r' ' *:!z '-.." - .. . ,- . r.' -. '-/Thereappears to be agreement'that :we ought to bave a Material Safety Data Sheet on MONOKOTE. The purpose of this memo is to present two options for the format with the objective of accepting one of the two, so that we can respond to pending requests. It may also be possi ble to use option 1 plus the technical bulletin on a selective basis. Both versions face up to the two key issues "Airborne Asbestos Fiber and Free Silica" in the manner outlined below: M.S.D.S. SECTION II - HAZARDOUS INGREDIENTS Option #1 The physical handling of MONOKOTE fireproofing during application can create a nuisance dust level in excess of OSHA Standards. Normal in dustrial dust control practices should be followed. Option #2 Contains trace quantities of Tremolite, a natural occurring impurity, classifiable as asbestos by OSHA Regulation 1910.1001 (refer to attached Technical Bulletin). The physical handling of MONOKOTE fireproofing during application can create a nuisance dust level in excess of OSHA Standards. Normal in dustrial dust control practices should be followed. j M.S.D.S. SECTION V - HEALTH HAZARD DATA | Option 81 TLV: Dust - Respirable Fraction 5 MGM/M3 - Total Dust 15 MGM/M3 Option 02 TLV: TLV: Dust - (Respirable Fraction 5 MGM/M3- Total Dust 15 MGM/M3) Asbestos 2 Fibers/cc 8 hr. TWA 10 Fibers/cc max. (See Attached Technical Bulletin) 15026908 I a.) Tremolite Levels - Our data base -- "Review of MONOKOTE fire proofing as related to Section 25910 of the California Health and Safety Code." This report quotes A. D. Little report that MONOKOTE may contain fiber at a level of 4 parts per million. b.) Jobsite Airborne Fiber Levels - The same report says "Fiber counts are of the same order of magnitude that NIOSH has established as the minimum, which can be reliably detected and so far below even future OSHA Standards as to be classed as not hazardous." c. ) Tne Marks Bill has been passed in California and contains exemption for products containing "less than 0.25% of naturally occurring contaminant." d. ) Thus, Option #2 should enable us to handle the sales problems of formally stating the fact of Tremolite contaminant. I feel that issuing a Material Safety Data Sheet now,based on available data, puts us in a better position to deal with the real world than ducking the issue and not issuing one. May I have your comments? Finally, we could consider the alternative of using only option 1 with the technical bulletin as a back up where needed on a selective basis. We would handle requests for Material Safety Data Sheets in the following manner: A simple,routine request for an M.S.D.S. (from any source) would be answered with option 1. In the event an inquiry went beyond this and specifically asked questions about a possible asbestos content in MONOKOTE, we would respond with the technical bulletin as a supplement to the option #1 M.S.D.S. We could further control this supplemental response by requiring that it come from Cambridge Quality Assurance only and with the requirement that B. R. Williams be informed in advance of sending it out. RCE: M Attachment /i r i/' L ` ' I'tC - ' R. C. Ericson 15026909 A number of samples of MONOKOTE have been analyzed by three competent independent laboratories to determine if any asbestos is present. All three laboratories reported no detectable asbestos in MONOKOTE. The three laboratories are: (1) Arthur D. Little, Inc. - Cambridge, MA (2) Mount Sinai Hospital Environmental Science Laboratories - New York, N. Y. (3) Truesdail Laboratories - Los Angeles, CA In our own Grace laboratory, tremolite cannot normally be detected in MONOKOTE even when using sophisticated X-ray diffraction techniques. However, the theoretical possibility of tremolite being present led us to further investigations. An experienced consulting petrographer, who was assigned to this project, was able to find some evidence of trace quanti ties of tremolite in two out of seven samples of MONOKOTE, although in amounts too small to be quantified. In an attempt to quantify the tremolite fibers present in MONOKOTE, Grace funded a six-month research project at Arthur D. Little, Inc. in which a combination of the most sophisticated and up-to-date analytical techniques were employed to quantify the tremolite fiber present in these two samples of MONOKOTE referenced above. Arthur D. Little, Inc.'s re search results indicated that tremolite fibers were present, but at a level less than four parts per million, levels which are not generally detectable. This extensive research leads us to the conclusion that: Although tremolite fibers may be present in MONO)'.'DTE, they are present only at such extremely low levels as to be "de minimus" and clearly inconsequential. 15026910 Technical Bulletin (cont.) -2- 8/4/78; In spite of the foregoing, MONOKOTE might'technically be consic conflict .with any./regulation or specificationSbannijigiasbestos:'ihspiteS< iyumbe-'aiia^uisiqiflficant.anoant of tremolite*fibers;;Wnich might^be.-;jpresent^^^^i's<'/; jjjj^obsitg Airl|m^il>er/Levels ^ Grace has conducted counts during the' mixing and ' iK P are breathing 'zone air,' samples from MONOKOTE workers at MONOKOTE. job^; . , _ , ' .'. ; * ! - ... ,Vs;,vi- ' sites. They were collected on Millipore 37 millimeter diameter'filters V. /'/ with 0.8 micron pore size. The fibercounting/was' done in our/M^yti-./,^^'" cal lahoratorv usino ths st-aniismrl ohasA 'cnntrast'mirrnscooie:nt>thod'-aoi'>Sl j wl': v: 5 wi 7 K'-fKl- W0. Fiber counts taken by this method have an unknown error factor which has the "effect of overstating fiber jcounts./j .This is because existing analytical methods cannot differentiate;Vat these low fiber-sV^ levels, between the gypsum, glass and organic fibers which are part' J,<; of the MONOKOTE formulation. The test results//therefore, .include the'- measurement of other fibers in addition^to jaremolite which may-befefe^y present. Values obtained, therefore, are/considered maximum fiber,?4"r 4/ # s' count levels..^ /.v".;..,; ' /fe'-'' -.-o''- V In addition, fiber counts include background fiber levels ; characteristic of the air quality and asbestos fibers which might be introduced from water which is mixed with MONOKOTE. Actual fiber counts from MONOKOTE only would, therefore, most likely be lower. Grace's jobsite studies show fiber counts in the ranges listed below: Fibers/Ml. 8 Hr. TWA Max. MX Mixer Operator MX Sprayman 0.0? - 0.10 0.12 - 0.23 0.08 - 0.31 0.19 - 0.52 We believe that at the extremely low fiber levels which were measured (which measurements included counts of background fibers), MONOKOTE cannot be judged to be hazardous. The levels are not only far below today's Federal OSHA standards, but also far below the standards proposed for the future (.5.fibers maximum). In fact, the fiber counts measured when MONOKOTE is used are of the same order of magnitude that NIOSH has established as the minimum which can be reliably detected. a ii; In spite of the foregoing, because of the specific language of OSHA Regulation 1910.1001, 4 (f), the regulation can be construed to require 3 monitoring in any workarea where there is use of a material which contains ^ anV asbestos. | Conclusion j In any case where the application of MONOKOTE is being considered | and an applicable regulation or specification contains a requirement that the | product be certified to be "free of asbestos" (implying at any detectable j level, no matter how small) we would invite attention to the recent action of hhe State of California. This action was taken to alleviate unnecessary con cerns which result from a total and complete ban on asbestos. The California : regulation was ammended so that it now contains an exemption for products con| taining "less than o.25% of anaturally occurring contaminant." 15026911 v z oh( -m *?