Document ZnyQKKYg3nOyn4mo0mXgzvkXL

FILE NAME Manville JMA DATE 1973 DOC JMA271 DOCUMENT DESCRIPTION Marinite Board - Use in Excess of OSHA Standards - Minutes Memos Report & Letters Environmental Affairs Denver GHQ April 11 1973 Department W. R. Goodwin J. B. Jobe F. H. May Jr. R. H. Cuje E. M. Fenner W. F. Goodwin J. E. Hesse J. R. M. Hutcheson A. B. Marchant CC M. M. Swetonic - AIA File & C E. F. Marriner M.D. J. A. McKinney H. B. Moreno F. L. Pundsack Ivan Sabourin F. J. Solon Jr. - Chairman W. L. VanDerbeek W. C. Winblad G. W. Wright M.D. ACTION MINUTES ENVIRONMENTAL POLICY MEETING OF MARCH 30 COMMITTEE 1973 A copy of the agenda for this meeting is attached The action items that arose from the meeting are as follows 1 Prepare critique of by Marcus M. Key to Meeting in Atlantic G. W. WRIGHT the Report From NIOSH presented the American Public Health Association City N. J. on November 14 1972. - - . 2 If the Federal Register announcement regarding the reopening of the Asbestos Regulations for review states that this action is being taken because of new medical and scientific data and informatito henn a registered letter should be sent to the originator of the announcement requesting this data and its source - - E. F. MARRINER 3 When AIA sends its list of suggested candidatfeosr the Asbestos Regulations Review Advisory Committee to the Department of Labor they should recommend that if either G. W. Wright M.D. and I. J. Selikoff M.D. are chosen for the committee neither should be chairman - - M. M. SWETONIC 4 Determine if the Employee Safety and You Need to Know About Asbestos as should be printed and distributed to ~ - E. F. MARRINER Health Guide What prepared by AIA Manville employees ACTION MINUTES ENVIRONMENTAL POLICY MEETING OF MARCH 30 PAGE 2 COMMITTEE 1973 5 Prepare draft of an Ad refuting recent news articles on asbestos and health and containing positive statements on the uses of asbestos fiber - - F. J. SOLON J. B. Jobe brought up for discussion the request of the Industrial Products Division that the labels on THERMO 12 cartons contain the statement Asbestos Free The conclusion reached by the committee was that the wording Asbestos Free should not be used Instead the label could either say Made with Cellulose Fiber or Contains No Asbestos E. M. Fenner EMF emr Attach SM SMSM SM UM Manville Cor espondence Internal Correspondence Corespondence Environmental Policy To Committee Members Date September 11 1973 From Jan McGrath Environmental Committees 2 Copies Subject ENVIRONMENTAL POLICY COMMITTEE FRIDAY SEPTEMBER 14 1973 MEETING AGENDA Attached for your review is a list of the agenda items which will be discussed at the meeting on Friday The meeting will be held in the Large Board Room at 10:00 A. .. Luncheon will be served at 12:30 P.M. W. R. Goodwin F. H. May Jr. R. P. Carter R. H. Cuje Att G. E. M. Fenner W. F. Goodwin J. E. Hesse J. R. R. Hutcheson A. B. Marchant J. A. McKinney H. B. Moreno F. L. Pundsack Ivan Sabourin F. J. Solon Jr. C. J. Sulewski W. L. VanDerbeek W. C. Winblad G. W. Wright M.D. Bishop AGENDA ENVIRONMENTAL POLICY COMMITTEE FRIDAY SEPTEMBER 14 1973 Bal MEETING filting - filting free filting including 1 Reopening Asbestos Standard 5 Fibers vs. 2 Fibers per cc 2 AIA Annual Meeting Report 3 Update Duluth 4 Lewinsohn Matter 5 Customer and Association Presentations 6 Washington Contacts 7 FDA Proposed Talc Regulations 8 Upcoming Meetings Selikoff November 10 1973 Proposed N.Y. Academy of Science October 1974 9. 10 11 12 G. W. Wright Amosite Memorandum Policy Discussion Customer Assistance in Meeting Asbestos Regulations Quick Retrieval Library Position Papers JOEH JOEH ao E. M. Fenner F. J. Solon Jr. F. J. Solon Jr. F. J. Solon Jr E. M. Fenner R. P. Carter R. P. Carter F. J. Solon Jr. F. J. Solon Jr. F. J. Solon Jr. Jan McGrath W. A. Cooper To . Senior Staff From Paul Kotin M.D. W. VANDERBERK VANDERBERK W. 2 VANDERBERK Gir AFD Copies Re PROPOSED CHANGE TO ASBESTOS STANDARD cwremavs. Today October Administration 9 1975 the Occupational Safety and Health OSHA will publish in the Federal Register proposed changes to the job health standards on asbestos These proposed revisions will include | an . --reduction of permissible exposures to an hour weighted average of 0.5 cc --reduction of ceiling limit determined during any minute sampling period to 5 cc of --establishment additional requirements for regulated areas employee rosters hygiene facilities worker training and information programs signs and labels and , monitoring and medical surveillance programs --extension medical records to of the period for retaining monitoring 40 years or for the duration of the and employee's emloyment plus 20 years whichever is longer current retention period is three years for monitoring 20 years for medical records : Oe --exclusion of construction activities from the and revised standard continuing coverage of that industry under the existing standard . i 7 By far the most important change is the proposed reduction of the permissible asbestos to 0.5 hour weighted cc from the 2 cc average exposure to standard which was to take effect July 1 1976 for We are concerned by the proposal several reasons First by the haste with which the standard was proposed and the - apparent lack consultation with either industry or labor or even other appropriate offices within OSHA Comprehensive inquiries have failetdo identify the source of the pressure on OSHA to reduce the standard from 2 cc as planned for July 1 1976 to 3.5 f.cc. , Second customary procedures have not been followed in the development preparation publication and publication of this proposal For example of an economic impact statement usually precedes of a proposed standard however this procedure has been reversed in this situation IN YOUR REPLY REFER TO FILE The CommonwealthCommonwealth CommonwealthofMassachuseMttsassachusetts Department ofLabor andIndustries Gww Division of Cccupational Hygiene 39 Boylston Boylston Street Boston 02116 August 30 1973 Mr. Richard Goodwin President Manville Corporation Greenwood Plaza Denver Colorado Salon Fenni Fenni Fenni Fenni 2710 2252 2252 2252 Dear Mr. Goodwin a As you may know this division has made a number of studies of asbestos dust and fiber exposure of workers in your Billerica Massachusetts facility It is apparent from relatively recent epidemiological information that industry and the industrial hygiene profession have underestimated the potential of asbestos fibers for producing injury While most continuous exposures to asbestos fibers are at manufacturing facilities such as yours there are many exposures among the users of asbestos products which while typically intermittenarte also typically uncontrolled or at best inad- equately controlled We have recently had occasion to measure asbestos fiber concentrations at plants where MarMariininte iMaritnitee board was being sed by drilling sawing even handling Concentration Concentration Concentration ... asset an exce ofsts he value we have liter of air current OSHA standard have you the highest yound recorded being in of as opposed to the excess of 100 liters per milli- permissible ridfive We believe that this fact warrants a further investigation of asbestos exposure among users of your Marinite products We would therefore appreciate it if you could send us a list of your customers for this material in Massachusetts This information would be used solely for the purpose of investi- gating possible areas of harmful exposure to asbestos fibers among workers and taking the necessary action to eliminate such exposuze : If this particular procedure is not practicable standpoint we would appreciate any suggestions as to how we could proceed in this matter from your you can make . HBE s Very truly yours Herrey B. Elin Hervey B Elkins Director remem ne oe Third while the proposed revision biblia o big bliroga rap phh y oyf approximately 50 references none of these references contains data that were not known at the time the 2 cc standard was established At the recent International Congress on Occupational Health at Brighton England however Sir Richard Doll reported on the mortality experience for lung cancer in employees of Turner Brothers through 1974 and he indicated a lung cancer rate three times over that expected in asbestos workers At the same meeting Dr. Muriel Newhousien collaboration with her statistician Dr. Geoffrey Berry reported on the development of a . prospective mathematical model from which they concluded that the attack rate mesothelioma in the work populatioonf Cape Asbestos United Kingdom would be approximately 11 by percent This figure is significantly higher percent rate projected Dr. Irving Selikoff than the 7 for his highly exposed asbestos insulation workers and the more generally accepted rate of 4 percent in asbestos occupational groups as . a whole . These findings though do not provide support for the proposed reduction of the standard The assumption made by ; Doll that the Turner population was exposed only to 2 cc is not supportable by mathematical model fact The Newhouse data uses a that has serious limitations in the opinion of other recognized statisticians Manville adheres to the position that 2 cc the standard promulgated for implementation July 1 1976 is a level of exposure at which there is no hazard as measured by impact on morbidity and mortality justification for as well as the patterns In addition the feasibility of many other aspects of the proposed change are open to serious question In accordance with regulations Manville will respond to the proposal in the Federal Register within 60 days following which a public hearing will certainly be held - although it may be postponed until spring since an | inflationary impact statement must be published at least 30 days prior to our response any scheduled hearing while we are it is the recommendation of Health preparing Safety and Environment that M's position regarding the proposal be that the review and analysis of all scientific data available . do not support the proposed reduction of the permissible exposure to asbestos from 2 cc to 0.5 cc Le ae a a OY MEMO TO FILE MEETING WITH NIOSH People Asbestos Textile - Microfiber On January 4 a meeting was held to discuss 1 the asbestos industrial hygiene work and the textile operations in general and 2 the forthcoming study involving microfibers at Waterville 07. Those attending the meeting dealing with asbestos included Mr. Robert Curtis of NIOSH Mr. Phil Bierbaum of NIOSH Mr. C. L. DeBiase General Mgr IPD Mr. Stoddard Lane Production Mgr IPD Mr. Jim Nugent Manville Plant and Mr. W. B. Reitze Manager Accident Prevention and Industrial Health The NIOSH people were desirous in determining whether our textile operation in A building is a typical asbestos textile operation and whether all types of textile can be produced under the same stringent control procedures as we now have in operation in Manville I believe that we got across to the federal people the fact that our operation at Manville is very small and it does not contain a full product mix in textiles Messrs Curtis and Bierbaum were informed that in many cases we chose to discontinue a volume textile product line rather than work out an effective control procedure It was stated that while we did not doubt that by spending additional monies we could ~ control most textile operations however it was further stated that when it becomes economically unsound to produce a product it must be dropped from the line The possibility may well exist that for certain specific textile operations control may be extremely difficult or uneconomical and that the 2 fibers limit may therefore drive a sub- stantial portion of the asbestos textile business to the Hong Taiwan Japan area ' I would consider this portion of the meeting a success in that the federal people were made aware of the fact that 1 we do not have a typical operation and 2 the lowering of the existing standard to the proposed 2 fiber limit may cause substantial cutbacks in domestic production of asbestos textile products Fibrous Glass The fiber glass meeting was attended by Mr. Curtis Mr. Bierbaum and myself At this meeting it was learned that their projected physical examination of our people at Waterville has been postponed until May There was still some doubt as to whether it will ever be accomplished During the week of January 14 they are reportedly examining the population of the Corning plant in Santa Clara California They have his staff no further data on the exact protocol that Dr. Parnes and will use for the examinations As the time draws near a meeting is planned with Dr. Parnes to outline specifically what it is he intends to do at our Waterville facility Regarding the fibrous glass for some time Dr. Bierbaum criteria informed package me that which has been imminent during the month of September a letter was written by Dr. Marcus Key to Secretary Stender that the package would not be issued for quite some time They are reluctant to issue the criteria package until all the data is in on microfibers They have reason to believe that a work practice type of document would be more useful and therefore will shortly solicit further input from industry in the form of a request to be published in the Federal Register It was Bierbaum's opinion that the fiber glass package would not be released before January at present by NIOSH to piggy the mineral 1975. There is no plan fiber package on fiber glass These apparently will be two separate documents The possibility of a combination document was considered but apparently rejected W. B. Reitze CC J. Solon ,-