Document aB8nkErNz0kgOGoR8MLOZbxBR

To<N>mnMr- j. j. Sibley c^ivon ucc-Law Dept. Location 47th Floor 270 Park Avenue New York, NY 10017 Copy to ] September 29, 1980 Originating Dept. Calidr1a AsbeStOS Answering letter date Info for Files PLAINTIFF'S EXHIBIT Although the timing may be borderline, enclosed is a copy of a letter by J. W. Rawlings sent to certain customers in early 1972. Please note that a copy was sent to Harrisons and Crosfield in April. Jpkn L. Myers JLM:dal Enclosure A24 1 ! 6 UCC 016169 CUSTOMERS RECEIVING JWR/RG-244 LETTER Reio hold Chemicals Inc. 37T0//2 Attn: Mr. R. C. Sulick (TD) 701 - 707 Woodward Heights Blvd. Ferndale, Michigan 4S220 cc: Vince Morrow (Manager of Marketing & Sales Polyesters) White Plains, NY Glidden-Durkee 3/10/72 Attn: Mr. Ed Romay (Central Purchasing Director) 900 Union Commerce Building Cleveland, Ohio Conwed Corporation Attn: Mr. Earl Johnson Arch A C Street Cloquet, Minn. 55720 Copies ofi jwk LeTter were given, in ApriI / to W. Jackson (HAC) and K. Campbell (Montello), with instructions that they could use info verbally but not to copy for customers. - American Cyanamid 3/24/72 Attn: Mr. John C. Schlegel 1937 West Main Street Stamford, Conn. cc: Mr. Roy Verdey - Azusa Cargill Company 3/30/72 K * Attn: H. Nakano 2801 Linwood Road Linwood, California 90262 Cook Paint & Varnish Attn: Clark Niss 1400 Jasper Street N. Kansas City, Mo. 64116 Mameco Ind. Attn: Dr. R. Evans 4475 East 175th Street Cleveland, Ohio North American Rockwell A24 1 J 7 UCC 016170 Tzr.. UNION7 CARBIDE CORPORATION MIXING AND METALS DIVISION 270 PARK AVENUE. NEW' YORK. N. Y. 10017 James \V. Rawuugs TiormsiBiKT March 30, 1972 Cargill Company 2601 Linwood Road Linwood, California 90262 Attention; Mr. H. Nakano Gentlemen: Many users of asbestos have become justifiably uneasy about recently enacted and proposed federal regulations. Unfortunately, the publicity given to this governmental activity has tended to be of a sensational nature and has done little to place the question of asbestos toxicology in logical perspective. I take this opportunity, therefore, to state our firm belief that Union Carbide Corporation can comply with the regulations now applicable to our asbestos operations and with all reasonably anticipated additional regulations. Moreover, we believe that our RG-244 customers can, without undue burden, comply with these regulations as they apply to their operations. In this regard, it is our belief that if your facilities are designed to provide the protection required under present standards regulating exposure to styrene fumes and amorphous silica dust, that you will also meet the standards established for asbestos. With regard to the toxicity of asbestos, it is important to note that asbestosis and statistical excess occurrences of bronchogenic carcinoma have been recorded only in connection with massive long term exposures to asbestos dust. The risk of this type of exposure primarily occurs in asbestos mines and mills and in manufacturing operations where asbestos usage is several thousand tons per year. The risk of long term massive exposure is not typical of operations utilizing RG-244. As you are well aware, RG-244 is used in relatively small quantities and is A24 1 ! D UCC 016171 Cargill Company - 2- March 30, 1972 introduced as a small fractional addition to a strong binder resin on an intermittent basis. .t At the present time, regulations pertaining to asbestos exposure are in effect under the Occupational Safety and Health Act. In addition, proposed permanent standards under this Act vere published on January 12, 1972 and are now under review. Also, proposed regulations concerning asbestos emissions to the .atmosphere under the Federal Clean Air Act are under review. The ultimate scope and content of the regulations and standards under review should be determined by mid-year. At that time, we will be prepared to provide compliance information and assistance to our customers relative to newly adopted regulations. It is clear that the main thrust of the OSHA standards will be a limitation on exposure to airborne concentrations of various substances including amorphous silica, styrene and asbestos. Under the OSHA regulations now in effect, the basic asbestos exposure limit for any employee is 5 fibers per milliliter on an 8 hour time weighted average. This limit is known as a threshold limit value, or TLV. The present TLV for amorphous silica is -20 million particles per cubic foot, or 80 milligrams of Si02 per cubic meter with the weight usually limiting. Also, TLVs have been established for many other substances, all designated as "air contaminants", such as styrene, mica, talc and coal dust. The present OSHA regulations applicable to these contaminants indicate engineering methods should be utilized to obtain dust or fume control to the prescribed level where this is feasible. However, respirators can be used to control exposure to asbestos, as follows: Airborne Concentration (1) 8 Hour 15 Minute Exposure (2) Exposure (3) Required Mask Type Typical Mask (4) 5 max. 10 max. None Required 25 max 50 max. U.S. Bureau of Mines Schedule 21B. Negative pressure on breathing. Covers nose and mouth. Willson Model 1009 with R 520 Filter an M-S-A No. 86432 with Type H, Ultra Filter and others. UCC 016172 Cargill Company -3- March 30, 1972 250 max. 500 max. U.S. Bureau of Mines Schedule 21B. Powered filter positive pressure. Personal Environment Systems, Inc. Hobd 330 or 351 with 1900 Series filter. Over 250 -- U.S. Bureau of Mines Willson GA2fi M-S-A Schedule 19B. Type C Lead-Foe and others. positive pressure, air supplied. (1) Fibers per milliliter greater than 5 microns in length, as ^ - determined by the membrane filter method at 400-450X magnification (4 millimeter objective) phase contract illumination. Reference: Federal Register, 36(234); 1910.93a (Tuesday, Dec. 7, 1971). (2) 8-Hour time weighted average. (3) 15 Minutes in an hour for up to 5 hours in an 8-hour day. (4) Not a complete list, but a list will be sent upon request. Experiments which we recently conducted indicate that the TLVs . for both asbestos and amorphous silica may be exceeded during the introduction of the material into unventilated resin mixing tanks. The range of readings for asbestos and amorphous silica during the mixing operation were, respectively, 1.4 to 11.5 fibers per milli liter (average 5.0) and 24.0 million to 39.0 million particles of silica per cubic foot (average 30 million.) -Other readings for -asbestos fibers were as follows: Operation 7% Asbestos Fiber Count Range in Material per ML______________ Avg. Fiber Count ______ per ML Spraying polyester resin in styrene with chopped fiber glass - boat hull and shower stall fabrication. Hand sanding polyester furniture 0.4 to 0.5 0.8 to 1.4 0.05 A 2 4-1 2 C <0.1 1.12 <0.1 Power sanding 0.4 2.1 to 3.0 boat hull 2.5 UCC 016173 Cargill Company -A- March 30, 1972 We, of course, recommend that you have your own operations surveyed by a qualified industrial hygienist to determine existing dust and fume levels. In this regard, we once again state our firm belief that if your facilities are designed to provide the required protection from dust and fume hazards for silica and styrene, that you will also meet the standards for asbestos. The information set forth above is certainly not, and was not intended to be, an exhaustive analysis of present or proposed regulations and compliance procedures. We are willing, however, to meet with representatives of your company for the purpose of examining the presently applicable regulations and compliance procedures in detail. Very truly yours. James W. Rawlings. JWRjmc UCC 016174