Document a4yDRwE3LRG71MLw1n0njZ1jR

ML , /c. ^QRTH AMERICA ASBESTOS INFORMATION ASSOCIATION 1745 Jefferson Davis Highway, Crystal Square 4. Suite 500 Arlington, Virginia 22202 (703) 979-1150 3E PLAINTIFF'S EXHIBIT 3 December 1978 UC-2970 MEMORANDUM FOR: Messrs. Carson - Asbestos Corp. LTD. Carlson - Special Asbestos Co. Ciskowski - Jim Walter Research Corp. Coats - Calavaras Asbestos LTD Brown - Connell Bros. LTD. Bonner - Vermont Asbestos Group Gritzuk - Cassair Asbestos Corp. LTD Morgan - Continental Products Corp. Novak - Huxley Development Corp. Poutiatine -- Johns-Manvilie Corp.| ___--Rhodes - Union Carbide Corp. SUBJECT: Department of Transportation Final Rule on Transportation of Asbestos It will be recalled that the Department of Transportation issued a proposed rulemaking with regard to loading, shipping and handling of asbestos fiber in the March 2, 1978 issue of the Federal Register. By notice in the Federal Register of December 4, 1978, DOT amends its regulations for hazardous materials by issuing a final rule for transportation of asbestos. The new regulation is hurried to addressees without comment. It becomes effective April 30, 1979. An assessment of the enclosure is in progress and will follow *r. ^he near* future. s' u B.J. Pigrtgrt Executive Director cc: Executive Committee Standards Advisory Committee Mr. Filteau, QAMA Mr. S. Masuda, Mitsubishi, Canada LTD. Mr. Muth, ASARCO Sir Neville Stack, AIA \ Enclosure A ; 9 n o -j / UCC 016436 56664 [491D-60-M) Title 49--Transportation CHARTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DE PARTMENT OF TRANSPORTATION [Docket No. HM-190; Arndt Not. 172-41. 173-123. 174-33, 17J-7. 17#-#. 177-44] TRANSPORTATION OF ASBESTOS Miicillantoui Amendment AGENCY: Materials Transportation Bureau, . Research and Special Pro grams Administration, DOT. ACTION: Final Rule. SUMMARY: These amendments re quire shipments of commercial asbes tos fibers to be packaged in rigid, air tight or dust and sift proof packag ing. Except when the shipment is by private carrier, non-rigid packages, such as bags, must be palletized and unitized "using shrink-wrapping or strapped fiberboard wrapping.-These amendments represent minimum safety requirements and are Intended to reduce the risks to the public health associated with the generation of airborne concentrations of asbestos that may result from the packaging and handling of asbestos fiber ship ments in commercial transportation. EFFECTIVE DATE: These regula tions are effective April 30, 1979. ADDRESS: All written comments re ceived in this rulemaking action are available for examination during regu lar business hours In the Dockets Branch. Room 6500, Trans Point Building. 2100 Second Street SW., Washington. D.C. FOR FURTHER INFORMATION CONTACT: Douglas A Crockett, Standards Divi sion, Materials Transportation Bureau. Research and Special Pro grams Administration, 2100 Second Street SW.. Washington, D.C. 20590. phone 202-426-2075. SUPPLEMENTARY INFORMATION: On March 2, 1978, a notice of proposed rulemaking (HM-160; Notice 78-3) was published In the Federal Register (43 FR 8582) stating that the MTB was planning to exercise regulatory con trol over the transportation of asbes tos. Specific regulatory requirements were proposed for the control of cer tain forms of asbestos (e.g.. milled or crude asbestos fibers). No require ments were proposed for asbestos fibers which sure Immersed or fixed in a natural or artificial binder material, or for manufactured products contain ing asbestos. Interested persons were invited to participate in the rulemak ing proceeding through submission of written comments on the proposal to RULES AND REGULATIONS the MTB. All submissions. Including late submissions, that were received on the proposal were fully considered by the MTB in the development of this final rule. Need To Regulate the Transportation or Asbestos Several commentera felt that the MTB had failed to establish a need to regulate the transportation of asbes tos. One of the commenters suggested that there was no need lor the pro posed regulatory control of asbestos in transportation because the' "methods and procedures how in use for the packaging and transport of asbestos meet the requirements of Part 173. 24(AKsie) of the Transportation Act, that is `under conditions normally in cident to transportation there will be no significant release of the hazardous materials to the environment* and `the effectiveness of the packaging will not be substantially reduced * * * (t)he proposal contains no documentation to justify additional regulation." This commenter, while apparently believing that asbestos is a hazardous material, was incorrect in suggesting that asbes tos is currently regulated by the MTB; or In suggesting that-the purpose of Notice 78-3 was to Justify the addition al regulation by the MTB of asbestos in transportation. The transportation of asbestos is not now regulated by the MTB. It was precisely the purpose of Notice 78-3 that It should be. If. as the commenter suggests, the transporta tion of asbestos is now "in compliance with pertinent provisions of the Trans portation Act," this rulemaking action will formalize and insure In a uniform and systematic manner that this is the case. Another commenter stated that Notice 73-8 did "not establish a foun dation for regulation, in that it does not document, or even allege for that matter, the actual release of fiber during the transportation of asbestos." As was pointed out in Notice 78-3, the MTB has "no detailed information on the amount of asbestos fibers released during transportation." The MTB does not now regulate asbestos, and lias not therefore systematically collected acci dent data on the amounts of asbestos released in transportation or data on the frequency of such accidents. Most asbestos fiber, however, is currently shipped in bags, and it is undeniable that these bags can and do break, or can be and are being torn or punc tured. with a consequent release of some or all of the bag contents. It can be speculated, moreover, that if all of the 750,000 tons of asbestos annually shipped In the United States were packaged in. as one commenter states, the "standard package" of a 100-pound bag. and if as Uttle as one-tenth of one percent of these bags were damaged in transportation during the year (one out of a thousand) and if on the aver age 1 percent of the contents of the bags so damaged were released, the total amount of asbestos released per year would equal about 7.5 tons. These calculations give a general idea of the magnitude of asbestos fiber that would be released, given a 99.9 percent efficiency factor for "bag integrity" in transportation, and a 99.0 percent effi ciency factor in. minimizing the amount of asbestos released given a tear in the bag. The rather evident fact that asbestos has been accidental ly released during transportation has not been contradicted by anything submitted to the public docket on this rulemaking action. One commenter. for example, in discussing the use of open-bed trailers with side racks and tarpaulins to transport asbestos stated, that there is no evidence that the use of such trailers "has contributed tobag breakage and* the release of air borne concentrations of asbestos = fiber." The Asbestos Information As- soclation. an incorporated nonprofit organization representing 51 firms in the United States and Canada engaged In the manufacture or processing of asbestos-containing products and the. mining/milling of asbestos fibers, stated that with "the very large 1 volume of asbestos shipped, occasional I container damage may occur." - i Although several commenters who discussed this matter do not contend that asbestos has not been released in transportation, they generally are of the view that the amounts that are ' being released are not significant or of \ a sufficient amount'to pose an unrea- . j sonable risk to public health. The 1 MTB does not agree; it believes that j the amounts of asbestos fibers that j are being released now. or would be re- . leased in the future, in the absence of 1 these amendments, may pose an un- , , reasonable risk to health. . Several commenters were concerned with the statement appearing in Notice 78-3 that "asbestos in its sever al commercial forms, poses serious j health hazards to Individuals subject i to long term exposure to airborne as bestos concentrations." One com menter stated that "not all long-term exposures to airborne concentrations : pose any health hazards * *.*' An- I other commenter suggested that the I statement needed "more explicit defi nition" and that "reference should have been made to unanswered ques tions within the scientific community concerning mineral type, fiber size and smoking in the asbestos-cancer rela tionship." One commenter stated that there is a dose-response relationship between exposure to asbestos and dis ease causation, and that this conclu sion Is supported by an OSIiA state ment from its June 7. 1972 preamble FEDERAl REGISTER, VOL 43, NO. 233--MONOAY, DECEMBER , 197* P UCC 016437 A >9030 ) RULES-AND REGULATIONS 56665j to its standard for exposure to asbes timimUny trace element. The amend tos dust (37 FR 11318), The OSHA ments apply only to asbestos (n its statement Is that: "No one has disput several commercial form since it is ed that exposure to asbestos of high those forms of asbestos that have been enough intensity and long enough du firmly established as posing serious ration is causally related to asbestoals health,hazards to Individuals. A new and cancers" (emphasis added). Al paragraph has been added which though the MTB had also quoted this would define commercial asbestos as statement in Notice 7B-3, the words any material or product containing as underlined for emphasis had been in bestos that has commercial value be advertently omitted. Under these cir cause of Its asbestos content, and ap cumstances. some commenters appar propriate modifications have been ently felt that the MTB was asserting made In the amendments to reflect the view that because, according to this clarification. This new paragraph some commenters. asbestos is ubiqui Is identified in this amendment as tous, long term exposure to ambient paragraph (b) (paragraphs (b) and (c) levels of asbestos fibers poses serious in the notice are now paragraphs (c) health hazards to all people, without and (d), respectively). regard to their occupational or para- One commenter recommended that occupational status. It was not the in the scope of Notice 78-3 be amended tention of the MTB to assert this view. to Include, In. addition to asbestos That there are or can be "undisputed fibers, -'all mineral and man-made grave consequences from exposure to (fibers) which have been identified by asbestos" (37 FR 11318) does not depend on the questioned conclusive UH.- Government agencies, as being carcinogenic and which may pose seri ness of the evidence reported by ous health risk." On December 9, 1976, OSHA (40 FR 47652) regarding the po tential health hazards posed by lowlevel brief or intermittent exposure to' the MTB published an Advance Notice ' of . Proposed Rulemaking (41 - FR 53824) in Docket No. HM-145 entitled ssbestos. The MTB relies on the fore going Federal Register references for the general view that exposure to as bestos may pose an unreasonable risk to the public. "Environmental and Health Effects Materials." In that Notice, the MTB announced that it was considering whether new or additional transporta tion controls are necessary for certain classes of materials which are not gen Section 173.1090(a) and (b) - erally subject to the existing Hazard Several commenters stated that there are certain mineral ores, ore con centrates and milled mineral products which may have trace amounts of as bestos. or minor amounts of asbestos occurring as contaminants. They sug gested that these materials presented no risk to property and little, if any. risk to public health and safety In transportation. Moreover, since the packaging requirements proposed in Notice 78-3 applied to only certain kinds of asbestos, namely milled or crude asbestos fibers produced by an asbestos mill, they further suggested that only "commercial asbestos fibers" be defined as a hazardous material. The MTB recognizes that there are certain mineral ores, ore concentrates and milled mineral products, as well as ous Materials Regulations. The ques tion of whether all mineral and man made fibers, which have been identi fied by U.S. Government agencies as being carcinogenic and which pose an unreasonable risk to . public health, should be controlled in transportation will be considered In terms of the fur ther development and resolution of the issues associated with Docket HM145. Notice 78-3 however,.pointed out that a large number of comments were received in Docket HM-145. and that a considerable amount of staff evalua tion of these comments was still re quired before it would be possible to issue a notice or notices of proposed rulemaking for environmental and health effects materials, either on a comprehensive or on a selective basis. othpr products, that contain certain Section 173.1090<cXl) amounts of asbestos, and that the .commercial value of these minerals or products is not dependent on their as bestos content. The specific require ments in these amendments for the control of asbestos fibers In transpor tation do not apply to such materials or products, nor do they apply to as bestos as a waste product1 or as a con- Several commenters objected to the reference made to metal or fiber drums to illustrate the rigid packaging alternative for asbestos fibers. These commenters stated that the asbestos Industry has not developed the tech nology to Use this type Of packaging alternative; that available technology is not transferable to the use of metal or fiber drums; and that, among other Under Docket HM-145A <43 FR 22826. things, the use of this alternative May 25. 1*78), new standards and proce could generate far greater airborne dures were proposed for the transportation of hazardous vaste materials That proposal concentrations of asbestos than pack- would Include waste asbestos tr so identified by EPA under Section 3001 of the Solid source Conservation and Recovery Act (Pub. 'Waste Disposal Act as amended by the Re- U *4-8*0). aging and shipping practices currently ( in effect. As one commenter pointed out ,,. Commercial asbestos is flulfy. It is dimcult to peck this materia) in a rigid contain er. and, because the liber would, gradually compact during shipment, it would be dllll- . cult to remove It for Introduction into the manulacturtng process. It would also be ex tremely cumbcrsoiAe. it not Impossible, to empty rigid containers effectively and rapid ly Into hoods designed lor baga BplUage would no doubt occur and workers would be unnecessarily exposed to fibers. - Another commenter recommended that a DOT Specification 58 portable tank be included in the amended rule - as an acceptable package "for the transportation of asbestos-type prod ucts." This commenter stated that "with the use of equipment designed for the purpose, the D.O.T. 56 package can be readily filled or emptied with out release of any product dust to the atmosphere or contact with the prod uct by the operator." Another com menter insisted that only metal drums and not fiber drums were acceptable for the transportation of asbestos fibers. These commenters apparently lost sight of the fact that proposed $ 173.109<XcXl> does not "mandate." as one commenter suggested, or even en courage the use of rigid, airtight pack aging such os metal or fiber drums or even portable tanks. It provides ah al ternative method of shipping commer cial asbestos fibers. As was indicated in Notice 78-3, the MTB believes that its proposed non-specification packaging standards as applied to the transporta tion of commercial asbestos is an ef fective and efficient means of preclud ing potential problems associated with asbestos airborne emissions occurring during transportation; and that they are consistent with the standards of the EPA and the OSHA. Some of the commenters however were also appar ently unaware that the. transportation standards for the control of asbestos are designed to be comprehensive in nature such that, once the standards are promulgated, commercial asbestos cannot be packaged and transported in any matter not specified in the amend ments. If under more advanced tech nology the use of rigid, airtight pack aging would lessen the likelihood of airborne asbestos emissions associated with bag breakages under current in dustry wide non-uniform non-standardized packaging practices, then it Is necessary that alternative transporta tion standards be available so as not to preclude the development and utiliza tion of such.technoiogy. Although the public record on Notice 78-3 contains statements that the asbestos Industry is seeking to improve the technology involved in the shipment and handling of commercial asbestos so as to mini mize the possibility for the accidental release of such asbestos Incident to FEDERAL UGIITH, VCR. S3, NO. 233--MONDAY, DECEMBER 4, 1*7S . t UCC 016438 A ; 963 ! 56666 RULES AND REGULATIONS transportation. It Is by no means cer tain that the pace of such technologi cal improvements Is rapid enough or that the best, economically feasible technology Is being considered. How ever. the classification of asbestos as an ORM-C will, for the first time, re quire the submission of incident re ports to the MTB by carriers of any unintentional release of asbestos during transportation, and enable the MTB to monitor the safety perform ance record associated not only with the transportation alternatives availa ble under current technology as pro vided for by these amendments, but also with any Improvements In that technology. For these reasons, the substance of proposed { 173.1090(cXl) is being re tained but modified to reflect an even broader range of permissible rigid, air tight packaging alternatives. This sec tion now Is identified in this amend ment as 5173.1090(dXl) because of the addition of new paragraph (b). Section 173.1090(c)(2) Proposed paragraph (c)(2) of Notice 78-3 covered the transportation alter native of shipping commercial asbestos in bags when in closed freight contain ers. motor vehicles, or rail cars that were loaded by the consignor and un loaded by the consignee. Several commenters noted that, unless reliance was placed on using the rigid, airtight packaging alternative provided In the proposal, this alternative would pre clude the shipment of asbestos fibers by open-bed trailers. One commenter noted that there is "no evidence to in dicate that the use of open-bed trailers with side racks and tarpaulins has con tributed to bag breakage and the re lease of airborne concentrations of as bestos fiber." Another commenter noted that the' type of bag permitted by proposed paragraph (CM2) was not specified, and that the shipper could package asbestos In burlap bags, or very thin paper or polyethylene bags which could permit asbestos fibers to be easily released into the air during transit. Another commenter was con cerned with "small volume users of as bestos and customers who, from time to time, require sample shipments for trial production runs of a few hundred pounds." and who under 173.1090(c)(2) would be forced to ac quire the exclusive use of a railcar or highway trailer, or rely on the alterna tive provided by 173.109(XcXl). Given the lack of detailed data on the amount of asbestos fibers released in transportation and the circum stances and causes for such release, the MTB is In general agreement with the thrust of these comments; accord ingly, a new paragraph (d)(2) recog nizes less restrictive handling of bagged asbestos than was proposed. Sections 174.840. 175.640. 176.906, 177.844 In these Sections. Notice 78-3 had proposed that, incident to Its transpor tation. asbestos must be loaded, han dled, and any asbestos contamination removed. In a manner that will prevent occupational exposure to airborne as bestos particles (emphasis added). Some comm enters objected to the word __ "prevent." believing that this word was Intended to mean completely precluding the possibility of an acci dent occurring in which asbestos fibers would be released; or completely iso lating people involved In the transpor tation. loading and unloading of asbes tos from exposure to asbestos fibers from whatever source such fibers were generated. One commenter pointed out that with "the very large volume of asbestos shipped, occasional con tainer damage may occur." Another commenter pointed out. although in a somewhat contradictory fashion, that since "asbestos Is ubiquitous," there fore "airborne levels of asbestos fibers can be present in any place of employ ment. regardless of whether or not as bestos or products containing known quantities of. asbestos are handled" (emphasis added). The Asbestos Infor mation Association in Its commentsstated that "asbestos is ubiquitous, and there'are no workplaces where there is zero occupational exposure to asbestos" (original emphasis). If Notice 78-3 was not as clear as It might have been on this point, it is only necessary to say that the basic purpose of these amendments is to minimize the exposure to airborne as bestos particles accidentally released during or incident to transportation; and appropriate changes to Parts 174. 175, 176. and 177 have been made to reflect this purpose. ORM-C Classification Notice 78-3 proposed that the classi fication for "asbestos" would be as an ORM-C. (Other Rczulated Material. Group C). Several commenters were uncertain and . concerned about the marking requirements associated with ORM-C classifications. One com menter noted that the designation ORM-C would "carry no meaningful warning to the person handling or opening the package." Another noted that the present regulations of the Oc cupational Safety and Health Admin istration (OSHA) on labeling require ments for asbestos convey much more Information than an ORM-C marking requirement. These commenters were | apparently . not completely familiar with the marking requirements associ ated with ORM-C designated materi als. The ORM-C marking not only warns when a package contains haz ardous material, but It Is also a certifi cation by the person offering the i package for transportation that the material is properly described, classed, packaged, marked, and labeled (when appropriate) and In proper' condition for transportation according to appli cable regulations of the Department. Neither function precludes or pre- ; empts OSHA labeling requirements or i creates "contradictor)' regulatory re- t quirements for labeling" as one com menter suggested. For these reasons, no changes have been made with re- [ sped to any marking requirements for 1 asbestos packages. Economic/Inflation art Impact In reviewing the potential economic [ and inflationary Impacts associated ! with the final rule, the MTB has de- ` termined that such impacts will be j minimal. Based on the comments re- ' celved, and the consequent modifica tion of Notice 78-3, the only economic costs associated with final amendment pertain to the reporting requirements to be submitted to MTB on the acci dental releases of commercial asbestosfibers during or Incident to transporta tion. The absolute annual magnitude ! of these costs will be. of course, a func- j Uon of the total number of incident reports that are submitted on aedden- \ tal releases of asbestos fibers; but in view of the undisputed grave conse quences from exposure to asbestos I fibers, these reporting requirements will not impose an unnecessary burden on the economy, on individuals, or on public and private organizations. In consideration of the foregoing. Title 49, Code of Federal Regulations, Parts 172. 173. 174. 175. 176. and 177 are amended as follows; PART 172--HAZARDOUS MATERIALS. TABLE AND HAZARDOUS MATERF- ' ALS COMMUNICATIONS REGULA- ` TIONS 1. In $ 172.101 the Hazardous Materi als Table Is amended by adding a new ; entry, immediately following "Arsine," to read r-s follows: v FEDERAL REGISTER, VOL 43, NO. 233--MONDAY, DECEMRER 4, 1971 UCC 016439 A i 003-' l910-0-C] I IT M o i lUzardnuK m aterial! table. K O IIA I ItO U T W , VOL 4J, NO. J M --MONDAY, O fC tM Itl 4, 1171 RUi.ES AMD REGULATIONS *4 f M c t o. 'X R ww V *J 4 3 s cr 38 V xs *4 M to J ERR ft M ft # e a > 4A . w wR O ti ft. UR ft g> X * R C 33 Vo U ft e* e 3 me H 2 u M ow ~a M x W U >4 U e >* uom i U to bo -- u ft to* UW to to U A U to to R C-- R w o fl V R M -m* r er ft -4 U U1 -4 ft a m to m J cv *4 <H R U 3W m jr*. K J{ ft ^ B ft R R 14 to | wu R C* e o m* ft RR N- U X u *R < R *4 R a L OU --ca ^ 33 x e>4 u * -4 M J W>^ OMR R to - R er RR -4 ft , ^ -- *ft R >*- S w R> o R MX X to M 4 ^ N *R w 3 ml " 3 U <4 3 O K o o* o K NR -4 o a* o o NU R C O X 4 " ' ** - *% - t . .. . ** ^ U ft R *4 U SB ^ f . w g v4 *. ft W ft 31 ft ^C w R ft * 4 a to a *4 ** JZ ft ft ! ft 9 ft oo TJ W b ft ft e S3 ft -4 . - Vs o o w *0 R ft R < .ft < , 56667 UCC 016440 A < 963 3 ES663 RULES-AND REGULATIONS- PART 173--SHIPPERS--GENERAL RE and unloaded, and any asbestos con QUIREMENTS FOR SHIPMENTS AND PACXAGINGS 2.Section 173.1090 Is added preced ing Subpart N to read as follows; -- tamination of aircraft removed. In a' manner that will minimize occupation al exposure to airborne asbestos parti cles released Incident to transporta $ 173.1090 Asbestos. (a) Asbestos includes any of the fol lowing - hydrated mineral silicates: chxysotLle. crocidolite. amoslte, anthophyllite asbestos, tremoiite asbestos, actinolite asbestos, and every product containing any of these minerals. tb) Commercial asbestos is any mate tion. (See {173.1090 of this sub-j chapter.) FART 176--CARRIAGE BY VESSEL 6. Section 176.906 is added to read as ^follows: ___- rial or product containing asbestos that has commercial value because of Its asbestos content. $ 176.904 Stowage and handling of asbes. too. (c) Asbestos which is immersed-os-- - - Asbestos- must be stowed, handled.] fixed in a natural or artificial binder and unloaded, and any asbestos con material (such as cement, plastic, as phalt, resins or mineral ore) and man ufactured products containing asbes tos or any materials or products whose _ tamination of vessels removed, in a] manner that will minimize occupation al exposure to airborne asbestos parti- j oamnercla1 value is hot dependent on-? des* released incident- to- transporte-i their asbestos content, are not subject"' tton. (See g 173.1090 of this sub- to the requirements of this sub chapter.) chapter. (d) Commercial asbestos must be of fered for transportation and trans ported in-- PART 177--CARRIAGE BY PUBLIC | (1) Rigid, airtight packagtngs such HIGHWAY as metal or fiber drums, portable tanks, or . 7. Section 177.844 is added to read as ` (2) Bags and other non-rigid packag- follows: lngs that are dust and sift proof. When transported by other than a pri .$ 177.344 Other regulated materials. vate carrier by highway, bags and"" other non-rigid packagtngs containing Asbestos must be loaded, handled, asbestos must be palletized and unit- and unloaded, and any asbestos con i'.ed by methods such as shrink-wrap tamination 'of transport vehicles re ping in plastic film or wrapping in- fh moved, in a manner that will minimize berboard secured by strapping.. occupational exposure to airborne as bestos particles released incident to PART 174--CARRIAGE BY RAIL 3. A Subpart M Heading is added im mediately following 174.812 to read as follows: transportation. (See f 173.1090 of this subchapter.) (49 T7.S.C. IMS. 1804. IMS: 49 CTO l.SSCe).) Non.--The Materials Transportation Suboort M--Detailed Requirements Bureau has determined that these amend far Other Regulated Materials ments do not require a regulatory analysis under the items of Executive Order 12044 4. Section 174.840 is added to read as and DOT Implementing procedures (43 TO follows: 95321. A regulatory evaluation Is available for review in the docket. J 174-S40 Special loading and handling re quirements Tor asbestos. Issued In 'Washington, D C, on No Asbestos must be loaded, handled, and unloaded, and any asbestos con tamination of rail cars removed, in a manner that will minimize occupation al exposure to airborne asbestos parti cles released incident to transporta tion. (See $173.1090 of this sub chapter.) vember 27, 1978. L. D. Santman, . Director, Materials Transportation Bureau. (TO Doc.*73-33771 Piled 12-1-78:8:45 am] PART 175--CARRIAGE BY AIRCRAFT 5. Section 175.640 is added to read as follows: 175.640 Special requirements for other regulated materials. Asbestos must be loaded, handled, UCC 016441 A i 9 6 8 *+