Document b5RaabVa8MZQpRezgq1r1M94k

MEMO R A N D U M TO: Messrs. T. Dougherty h. A. Miller R. W. Stobaeus 3. K. Barton J. E. Skvarla N. J. Setter R. T. Larkin distribution w. T. Cohan J. A. Riddle K. V. Wood L. F. Crow G. C. Brice DATE: September 9, 1966 CC; Gentlemen: L. S. O'Rourke D. S. Kamens SUBJECT: T. J. Hall K. West H. F. Reichard/R. G. Woolery w6. A. Riddle G. Vessels 0 J. Derbecker Shifters 0 P. R. Chestor. T. F. Frangos A. A. Andrade F',e J&fit ^ A:, oescoc- Toxicoiogv DECEIVED SEP L2 1966 L'.C.C, - , METALS Ojy " ` " -------'* A : If* ` Attached are "tear sheets" from some of the most recent publicity in respect to the subject. The one article appeared in the September 10 issue -of . CHEMICAL WEEK; the other was passed along to us by Peter Cheston, and appeared in the LONDON SUNDAY TIMES of August 14. , There is no doubt this kind of publicity will persist, and it is important that its inapplicability to our products and our applications not be missed by our customers ana prospects. You have some positive positions you can and should Cake with your customers: 1. It is important that you continue to use Dr. Dernehl's "Asbestos Toxicology Report" as well as the statements made by the Food and Drug Administration (Department of Health, Education and Welfare). I am attaching copies of each; if your file supply of these is depieced, you can either run off copies or get addi tional from us. 2. In the CHEMICAL WEEK article, if we look at the summary of "sources of airborne asbestos", we see that, to our knowledge, our products now are used only in modest amounts in ceiling and floor tiles, and here in rela tively low concentrations. Further, these are applications . employing particularly good resin binders, making the loss of asbestos co the air from such compositions appear highly unlikely. UCC 023078 L 2- - 3. You will recall (my memo March 26) that there has been medical literature reference to the association between cancer and polycyclic aromatic organic compounds found with certain sources of asbestos -- among them jute oils from sacking materials, and 3,4 benzo(a) pyrene. Union Carbide uses no jute bags. Analytical tests have established the absence of organic material with Union Carbide asbestos. Some time next week, we expect microanalyses to show specifically no detection of polycyclic aromatic compounds with Union Carbide asbestos of our different grades. 4. Please note the primary concern in these publications deals with "airborne asbestos" - and Dr. Demehl has stated clearly that "while asbestos dust in excess of the Threshold Limit Value is potentially harmful, as are many other dusts encountered in industry, it is as readily controlled as other dusts and it can be used safely with appropriate precautions". We should take the positive position, important to our customers, that Union Carbide produces and supplies this commodity in pelletized form, a major step in assisting the user to control his own dust hazards. We feel certain this factor has been a prominent one in the decision of certain of our floor tile customers to shift toward . use of Union Carbide product. Very truly yours. A.E.Pufahl:dk attach. UCC 023079 Taking Giant Steps Two chemical process companies took giant steps toward diversifying into the oceanography field last week, and two paper companies with com bined sales of nearly $1 billion/year reached a tentative agreement to merge. (1) Bendix Corp. (Detroit) ex panded its oceanic activities by ac quiring for an undisclosed amount of stock Marine Advisers (La Jolla, Calif.), producer of oceanographic in struments for petroleum and utility companies, state and federal agencies, and firms engaged in scientific pro grams. ' (2) Fluor Corp. (Los Angeles) and B. L. McFarland and Associates (Fort Worth and Midland, Tex.), a group of five companies involved in offshore and onshore drilling opera tions, have agreed to merge, subject to stockholders* approval. The Mc Farland group operates five offshore drilling rigs in the Gulf of Mexico. (3) A tentative agreement to merge has been reached by U.S. Plywood Corp. (New York) and Champion Parers, Inc. (Hamilton, 0.). It is sub ject to both directors' and stockhold ers' approval. The corporate identities oetb companies will be preserved. 7!educing Gas Rates The Federal Power Commission has ordered El Paso Natural Gas Co. and Transwestern Pipeline Co. to reduce by S17 million/year the price of na tural gas , in the southern California market. The rate cut stems from the July 26 decision in which FPC turned down the application of Gulf Pacific Pipeline Co. (a Tenneco subsidiary) to supply gas to the Los Angeles area (CW, Atig. 6, p. 20), Gulf Pacific lest week filed for a rehearing. El Paso and Transwestern were told they would have to lower their rates to reflect the lower costs result ing from the bigger deliveries pos sible in the expanded system. At the same time, FPC said it would conduct further proceedings to decide if cus tomers should get additional benefits resuming from more liberal deprecia'.'Or. allowances. -PC has given the companies 45 i'.v.'s to show cause why the reduction should not take place. Sources of airborne asbestos Asbestos-lined ducts used in centrally air-conditioned buildings. Asbestos ducts and insulation in home central-heating plants. Motor vehicle braise linings and clutch plates. Auto undercoatings. Asbestos ceiling and floor tiles. Asbestos shingles and sidings. Construction and demolition Fitting, cutting, and removing asbestos-filled wallboards and floorings, piping and insulation. Incineration of asbestos-filled scrap. Improperly filtered effluent from asbestos processing plants. The asbestos industry--whose end products are valued at more than $500 million/year--may be in for a shakeup. It could come in the form of federal legislation limiting the use of asbestos, because asbestos has been ac cused--though not yet "convicted"-- as a significant health hazard. Prob able contender for asbestos markets: plastics. Recent studies have convinced U.S. Public Health Service specialists and other medical authorities that about 40% of all Americans have mild, chronic cases of asbestosis, even though most of them never worked directly with asbestos. Unlike other airborne dust particles, asbestos fibers have the ability--al most as much as activated carbon-- to absorb polycyclic hydrocarbons and arsenicals. Furthermore, says USPHS, in the past 30 years the as bestos-related cancer rate has in creased sixfold. The Inferences: While the average asbestos worker is well protected, the man on the street is not. The 3x1micron asbestos fibers in his lungs can come from a variety of sources (table, above). And medical experts say there's no way to assess hydrocarbon content in those lung deposits. American Cancer Society research ers feel certain there is a synergistic relationship among airborne asbestos, smoking and lung cancer. They reason that the nondegradable, hydrocarbonsoaked fibers may well be a constant source of lung irritation. PHS officials think it may take them up to five years to establish asbestos' true role as an air pollutant. However, Congress may act before the research is. finished. Says Repre sentative Robert Watkins (R., Pa,): "We've seen enough evidence al ready. Asbestos will never get a clean bill of health. With just a little more data we'll move for controls and strict ones," Some form of asbestos control is in the offing, public health officials are certain, if only part of a larger dean-ambient-air program. However, there is the danger that Congress may enact rigorous controls on the quanti ty of asbestos that could be used. In that case both Canada and U.S. asbestos products manufacturers would be hard hit. Of the five forms of asbestos mined today, chrysotile asbestos holds the predominant mar ket position because of its insulat ing and processing qualities. Canada produces more than 80% of the chry sotile asbestos used in the U.S. In both countries, a number of serious dislocations would occur. At present, there is no known ma terial that could fill all of asbestos' strategic roles. On the other hand, should federal controls merely call for higher standards for hinder? and shieldings, that would spark a rise of new products, with plastics tr.kh'g the lead. Reason, say industry spokesmen, present polymer technology could easily turn up products to replace as bestos in most end-uses, 32 CHEMICAL WEEK Septembe' 1C, ICES UCC 023080 ; i f V v i-., O I i"!I !e T' By Br Alfred Bvvrc ] REGULATIONS which acknow- There arc three typer- of ledge that, occupational exposure asbestos used conuaerrisLy-- , to asbestos is causing Oift most cliiysntile. cfociuoiiie and amosito l important industrial cancer of our --whose possible hazards arc now i time will bo introduced next week being esarsned in the laboratory by Miss TvTaryai'ot i lerbi.-.Gii, Mini* ami ;:,e drill, Vfiih ; v Gib, ; StCt' Ilf SiH'iul .V'CUi'ilj'. ru.'iii mail, the lug i i.,;. .egg i gih.ii ' I'rmu Ali;:ir,t `.it! |In* tumour > IlilllU'll ... lll'j . I. l 11 -1 11 in1 i11 111;ii 1 on a 11 (ire- - 'ibri! disease," so iliul. asbestos Workers ll;..'.;m.-.t l ';. i - - -i 1.-. .a VU.g: e u- Iheiniiigl -.liiseir, ill ..i V.i:. v.i.rw otdv i - n e ivjir m lilur p, . .vm . Monies in ho;nh .\i;n\. 1. r.o v. in coutriict it as a resuit of aiready shown font Lite i .e.. .. is j tiivtr occupation after a certain more common m the noigt.'.iour* ! diiie wl'.'i be eligible tor industrial hood of mines producing vroc.do- ! benefit. Mesothelioma is an uu- lite tlian amusite. To complete the i usual Tumour of Urn pleura-- picture tin! committee are rmsunns : covering the lung--and of similar to see ;i similar study performed tissue lining the abdominal in Canada in relation to mines \ cavity, and is invariably fatal. producing chrysoiile. ! Several steps are being taken to- Pathologists in British hospitals | wards discovering the full ciTeeis are also going hack through their I of this recently. * recognised records in see if mes'o Ihe limns is | disease so that measures to pro* a 11 new " disease associated with I vent, it can in; devised, tim cinuinercial use of m be a os, A.',' register of 'all pant and and checkin;: if it is peculiarly present, cases occurring in Ihilain related tu certain districts. They . has ocen set up by the Medical are also studying the incidence ; Research Council's I'neunio- of asbestos particles in iubes : coniosis Research Unit, directed examined post mortem. In cities ! by I)r. J. C. Gilson, in Cardiff. of tiie U M, Mouth Africa and They have added 70 new cases Britain the lungs of middle-aged to their original nucleus of 120 and older people have been found I since the Sunday Times broke the to contain asbestos bodies in from | news of tins epidemic on October 5 to .llr per cent, of cases, Hn! ;2i, I Olio, tine hosptlal in Lon the medical siyniiicnrnv of this, if don and aimiher in lirlfasr are any, remains In be decided. each admitting an averagi* of one new ctt.se a month. Advised by a committee of experts, hue Ministry of Labour | An average of 40 years usually is drawing up a new code of elapses between exposure to regulations designed to give I asbednx ami the appearance of persons working with nsbe-.fos J ilie growth. Exposure for only more protection than they have- two or three months may cause had from the general factory the cancer. Living near an no'ulmions, A.sboslos is now used j asbestos work's predispose:; to to mak.; "niters, rno/biy, tiles, i mesothelioma, and relatives of brakp-linjr.cs and numerous other I asbestos workers can also get it tilings not envisaged when Ihe | through inhaling asbestos fibres risk of asbestos's was first given off the clothing of their rer.l used, menfolk. Tiie of.ieial propn.sriis will . Much patients were not Winking therefore include several occupa with asbestos, so they will not tions to which not enough thought ! he eligible for compensation i,`v riviMi ;:i lumvi toe industrial Injuries Act standard's of dustiness vtii pre of 1.1)47. Incredibly, perhaps, sumably he proposed for workers l, i':-'' are also other mesothelioma exposed to special risk, such as vicuna; wim are not eligible under tho.-e in ii.e lextile ind'-istry i ; the new regulation' because they 'a-......iged in biggin'.' hot ... worked'for a short tune in ihe It :s n ii 'il that ihe firs; official industry only before the new' Art proposal; will be made known by.' ; : ( ji'Vt', ill1 ' .:f ; ii i . ., UCC 023081  i'iii UK3C^! CARBIDE CORPORATION 270 PARK AVENUE, NEW YORK, N. Y. 10017 ASBE STOS TOXICOLOGY REPORT It has been known for many years that seme persons working in asbestos production were prone to develop a disabling lung disease. In time, this condition became known as asbestosis and was related to exposure to high concentrations of asbestos dust. With further experience, it was found that men could work with asbestos without development of lung disease if dust concentrations were kept below a certain level. It is now gen erally accepted that a man can work a 40-hour week for a lifetime without developing asbestosis if the asbestos dust particle count is kept at or below 5 million particles per cubic foot of air. This dust concentration of S million particles per cubic foot of air is the Threshold Limit Value for asbestos, and no cases of asbestosis are known to have occurred when exposures have been maintained at or below this level, despite large-scale utilization (now approaching one million tons per year in the U.S.A.). This concentration of dust is generally not visible in the average work area unless a beam of light causing a Tyndall effect is present. Usually the dust concentration must be from 8-10 million particles per cubic foot before its presence is visible in average lighting conditions. Several years ago, it was reported that there was an increase in the incidence of cancerous tumors, especially of the lung, associated with asbestosis. Recently there have been reports of some cancers occurring in individuals exposed to asbestos dust, but who have not developed clinical asbestosis. It is believed by most authorities that these cases have been associated with exposures significantly exceeding the Threshold Limit Value. A major manufacturer of asbestos products who also mines asbestos has not been able to show an increase in cancerous growths in men working where dust concentrations were maintained at the Threshold Limit Value. Control of asbestos dust exposure is therefore necessary. The control methods are the standard ones applicable to a variety of dusty operations. They include closed flow systems, wet processes where possible, and adequate exhaust ventilation where openings in the system are necessary. Pelletizing is sometimes used to improve the handling character istics of otherwise dusty materials. Where satisfactory containment to stay within the Threshold Limit Value is impractical or impossible, efficient and reliable respirators are available for the protection of the employee. A program of environmental monitoring is highly desirable to determine that Threshold Limit Values are not being exceeded. In paper manufacturing, it would be desirable to know the dust concentrations where the asbestos is dumped from bags into the pulp slurry. Concentrations should also be determined where dusting occurs in finishing products. While Initial dust determinations should be made at frequent intervals, once the level has been established as satisfactory, the frequency may be extended to occasional tests to assure continuation of a satisfactory condition. UCC 023082 -2Pre-employment and periodic physical examinations of workers are desirable. These should include chest X-rays to insure that the worker has no chest condition prior to work with asbestos and to determine that no lung changes are resulting from work with asbestos. It is believed that the addition of asbestos at the proposed levels during the manufacture of paper products would be harmless to the consumer. Total dusting would have to be well in excess of any levels acceptable to the consumer for the asbestos concentration to approach the Threshold Limit Value. In conclusion, while asbestos dust in excess of the Threshold Limit Value is potentially harmful, as are many other dusts encountered . in industry, it is as readily controlled as other such dusts and it can be used safely with appropriate precautions. Carl U. Dernehl, M. D. Director of Toxicology K. S. Lane, M. D. Assistant Director of Toxicology UCC 023083 Our Law Department advises us that the attached exchange of letters with the Food and Drug Administration means that FDA is in agreement with us that the use of asbestos fiber as a component of paper and paperboard used in contact with food is safe and is in compliance with the Food and Drug Act and that no specific regulation under the Food Additives Amendment is necessary. Our letter to FDA is dated October 31, 1963. Their reply s dated December 6, 1963. The correspondence is between Mr. Scriba of our Law Department and Mr. Cassidy of F.D.A. UCC 023084 DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE FOOD AND DRUG ADMINISTRATION WASHINGTON S5;D.C. 20204 December 6, 1963 Kr. George T. Scriba Union Carbide Corporation 270 Park Avenue New York, New York 10017 Dear Hr. Scriba: Reference is made to your letter of October 31, 1963, relative to the status of an asbestos fiber as a component of paper and paperboard. He concur that when used consistent with the principles of good manufacturing practice asbestos as an inert filler in paper and paperboard does not have food additive status. Therefore, there is no necessity for a regulation to prescribe the use of such asbestos fiber as an inert filler in such paper and paperboard. Sincerely yours. Frederick A. Cassidy Food and Drug Officer UCC 023085 UNION CARBIDE CORPORATION" Lav Dspahtment . ' 270 PARK AVENUE NEW YORK, N. Y. 10017 .V '" ' < . October 31# 1963 Food and Drug Administration Washington 25/ D.C. Re: Asbestos Fiber Gentlemen: . . (1) This is to inquire whether you are in agreement with us that.the use of asbestos fiber as an integral component of paper and paperboard does not result, and may not reasonably be expected to result, directly or indirectly, in its becoming a component or otherwise affecting the characteristics of the food when the paper or paperboard is employed in contact with food. (2) If not, whether you are in agreement with us that this use of asbestos fiber is generally recognized as safe among ex perts qualified by scientific training and experience to evaluate its safety. . (3) If not, we ask you to file th3 letter as a petition for a regulation under Section 409 of the Federal Food, Drug and Cosmetic Act stating that this use of asbestos fiber is safe. We propose to sell asbestos fiber for this use. Responsible paper manufacturers tell us that it improves the quality of paper and paperboard for certain food contact use. We base this petition on the generally known physical characteristics of asbestos fiber. While we write in terms of "asbestos fiber" without limitation In view of your presumed interest In a broad regulation, our company's direct present interest lies in chrysotile asbestos (a magnesium silicate). We attach a table entitled "Solubility and Dissociation Data for.Chrysotile in Water" from The Journal of Physical Chemistry Vol. LX (1955) page 1220, and our summary of "Properties of Chryso tile Asbestos.Fiber". We respectfully propose the following regula tion: *1121.___ Asbestos Fiber. Asbestos fiber may be safely used as a component of paper and paperboard Intended for use In producing, manufacturing, packing, processing, preparing, treating, packaging, transporting, or holding food. ' Very truly yours, UNION CARBIDE CORPORATION .- GTS:R enc. . ... By' George T. Scriba . : ' ' UCC 023086