Document b5O081GLjwR53B6LpDqv1aJd6

Inl*r Olltc* D, 0, 0b*;rly cc P. N. Bakallo J. T. Cunningham W. J. Digneit P D, Fndow W. A. Gaines J. W, Gutorman P. E. Prill E. B. GhuJtz W. L, Wt'bi'r Personnel and Orsanitation Stall February 2, 1977 Subject: OCHA Asbestos Standard OSRA standard lor exposure to asbestos dust became effective on July 7, 1972. An interim l'-voJ of du..t exjiocurc was cr.tiiblished for an 8-hour time weighted average (TWA) not lo exceed five fibers, longer than five micrometers, per cubic centimeter of air with a ceiling or maximum exposure level of ten fibers, longer than five micrometers, per cubic centimeter of air to which "no employe shall be exposed at any time...". . < t The standard also established an effective date of July 1, 1976* at which tine the TWA exposure level was reduced to two fibers, longer than five micrometers, per cubic mt--emetsribH+lZ+utu , '. As a result of a suit filed by the Industrial Union Department, AFL-CIO in . *. Vt:s` 197**, the court directed the Secretary of Labor to reconsider the July 1976 I <*| effective date for the lower two-fiber limit and the adequacy of the established 3-year retention period for exposure monitoring records. OSHA, through the * Federal Register, asked for public comment on these issues as well as any nev . i information having any bearing on the standard. During the period between the issuance of the standard in 1972 and the estab* ' * # lishment of the lower exposure limit in 1976, considerable work was done by ' ` numerous scientific investigators to determine more precisely the correlation > ' between disease entities resulting from asbestos dust exposure and the levels.^/ 1 of exposure. New developments were presented to OSHA urging the establishment \.VJ> ' of a lower exposure limit. i. V 'A *.1 f !fM` Thus it came about that on October 9, 1975> OSHA published In the Federal Reglotor a proposed rulemaking for exposure to aBbestos which lnoluded the Vfv. '7, ft lower 0.5 fiber TWA exposure limit. r.s.fi! Manufacturers using asbeotos in products supplied to us have indicated that , they cannot meet the 0.5 limit without considerable expenso for control measured',' * PQ8004 0618 SCF-FORD-1390 at their operations* and nomc have stated they would discontinue manufacturing. certain ports because of the added coBt for controls. '. Regardless, it in the opinion of thn Employe Health Services Department that any material, including asbestos, can be uoed oafely provided ve accept the cost penalty associated with tho control measures required to protect employe health. Pragmatically, the increased cost associated with the use of any one particular material oftentimes makes safer substitutes more attractive. ' ' Looking at the history of health standard development, ve estimate that the proposed lower limit will be established within the year. Further, since aobcotos is a carcinogen to human6, we recommend that a search for substitute materials be undertaken. In tho interim, cafe handling procedures and protec tive control measures can be applied to processes or material handling procedures that generate potential asbestos exposures. . ,