Document dQvw84QmdBbgngQxa2e6D1p36

m Johns-Marfvilie Internal Correspondence To: R. H. Cuje Date: May 18, 1981 From: J,. L. Fischer Copies: File/Chrono RFCDVEQflAY 2 5 8? Subject: ASBESTOS INGESTION STRATEGY A meeting was held on May 15, 1981 to review a proposed asbestos ingestion strategy. Those attending were: John Fischer, Pipe Division Jack Cran, Pipe Division Hal Olson, Pipe Division Dr. James Leineweber, H. S. .& E. Jim Reis, Asbestos Policy ' Wyatt McCallie, Legal Corporate Relations and Advertising were unable to attend due to previous commitments. The attached outline of an asbestos ingestion strategy was reviewed and, in general, met with acceptance. Some items where total concurrence was lacking and where additional action will be taken are: Advertising: Further input from Jerry Attridge and Curt Linke will be sought. H. L. Olson will contact Jerry and Curt and set up a meeting. Coating A/C: An analysis will be made by H. L. Olson of our present market area to determine the amount of this, market that is in "soft water" areas. Joe Jackson will be advised that J-M believes the ACPPA should develop an aggressive water policy guideline similar to. J-M's. Field Cutting and Machining: Additional effort should be expended by ACPPA to eliminate or minimize, the need to field cut and machine A/C. Abrasive disc cutters are still being used in spite of our efforts to stop the practice. -The development of a fitting that would connect to rough barrel pipe is a possible solution that H. L. Olsen will explore with the technical committee of ACPPA. CAPCO JEN 0032552 R. H. Cuje .May 18, 1981 Page 2 Our district sales managers have been requested to advise what they believe to be the most important functions of ACPPA and what, if any, additional actions they would like to see them take. Would you please review the attachments and advise if you have any questions. . After we have your input, the district managers' comments have been received, and the above specific items resolved, we will be in a position to meet with Earl Parker and Jim Reis to discuss the interrelationship between A1A and ACPPA and we should be in a better position to address the best method of approaching the EPA to finally resolve the ingested asbestos problem. The third page of the outline proposes a first-step' action plan in this regard. Once the ingested asbestos issue has been resolved, the ACPPA can finally get on with its important function of developing and promoting markets for A/C pipe. bf ii CAPCO JEN 0032553 Asbestos Ingestion Strategy I. Response to asbestos and health related to field problems: A. Our goal is to- prevent field crisis from developing by keeping those who need to know informed about the facts regarding the ingested asbestos issue before a crisis situation develops. See "Pipe Division Asbestos & Health Program" (attachment #1) B. 'In the event a field problem does develop: Follow the protocal for handling field problems contained in AACPP's "Management.Information System (M.I.S.) No. 12-80. (attachment #2) II. Advertising: ' . :T'' :' A. - AACPP should switch the major emphasis of their advertising to more aggressively addressing the asbestos and health problem, and their primary target audience to be the "secondary ring of in fluence" i.e. elected public officials. See M.I.S. No.'12-80. (attachment #2) . B. J-M advertising to emphasise features and benefits of A/C pipe. III. Response to formally proposed governmental asbestos re gulations: A.I.A. to assume prime responsibility with assistance as required by AACPP (See "Inter-relationships between A.I.A. & AACPP on the Asbestos & Health Issue" (attachment #3) IV. Coating the I.D. of A/C Pipe.. Where aggressive waters are to be transported thru A/C pipe our recommendation is to: A. Treat the water to a less aggressive state. B. Recommend a suitable internal coating if water treatment is not employed. , C. An analysis of material that can enter the water from our present .and proposed future coating to be analyzed by -the National Sanitation Foundation. A report by their toxicology group will be prepared. See "Division Policy on Aggressive Waters" (attachment #4) . V. Field cutting and machining - Compliance with O.S.H.A. asbestos dust regulations. ... < . A. J-M will develope a program to advise contractors and installers about OSlIA's asbestos dust regulations, and to develope means to minimize the need to cut and machine A/C pipe in the field. See Division Bulletin i CAPCO JEN 0032554 Asbestos Ingestion Strategy Page 2 A. "Asbestos & Health - Use of Abrasive Disc Cutters" (attachment #5) B. J-M will assist in disseminating recommended work practive manuals to contractors and installers. See Division Bulletin "Field Practices - Asbestos Cement Pipe" (attachment #6) C. To minimize A/C pipe field cutting and machining, J-M will promote the use of: . 1. P.V.C. closure sections in 6", 8", 10" & 12" sizes. ' ... 2. Short closure sections down to 19" long that will eliminate or minimize-the need to cut MOA's in the. field. VI. To finally resolve the asbestos ingestion issue, J-M in concert with AACPP will: A. ' Secure statements from State Public Health Officials regarding their policy about the use of A/C pipe and asbestos in potable water. We already have nine such letters. Our district health coordinators have an assignment to secure additional letters. B. Secure statements from recognized authorities in the medical and epidemiology field regarding the ingested asbestos and health situation. .. 1. ' From A/C Pipe Company Corporate Medical Directors. We have such a letter from Dr. Kotin. Dr. Mellon from Certain-Teed has promised to write a. similar statement. 2. From recognized authorities in .the medical and academic field. Dr's Kotin'and Mellon have promised to assist in this endeavor. C. Secure a favorable statement from AWWA on their posi' . tion regarding asbestos in potable water supply. There is a committee assigned to write such a state ment. Joe Jackson is on this committee. D. H. L. Olson will develope an estimate of the dollar expenditure by the U.S. water utility industry to count asbestos fiber in source and distribution water. These counts are going on now and accelerating at a significant rate. "If they continue, unchecked, it could well amount to an annual expenditure reach ing into the hundreds of millions of dollars annually by the 60,000 water utilities in the U.S. CAPCO JEN 0032555 Asbestos Ingestion StrategyPage 3 E. As soon as pra__ical a strategy meeting should be held by the following to develope the best means to use the information gathered in A, B, C & D to pursuade the new administrator of E.P.A. to announce, their studies of asbestos in water supply shows that the minute amounts of asbestos found in potable water do not indicate they represent a measurable health hazard. 1. A.I.A. - Jim Reis, Tom Dougherty, Bob Pigg,' Kirkland and Ellis. 2. A.A'.C.P.P. - Joe Jakcson, John Welch, Lewis & Gilman. 3. J-M Washington Affairs Office - John Linquist 4. J-M Denver - Curt Linke, Jerry Attridge, Wyatt McCallie and Hal Olson. CAPCO JEN 0032556 I'ip<> Division Asbestos t* lloallh Program Our basic asbestos '.iikI health plan is predicated on t.hc following- as being axiomatic. ` 1. There is no mensurable health hazard associated with the use-.of A/C pipe in the water utility market. a. Ingestion of asbestos in water supply is believed to be no lien 1th hazard. .> , b. Pipe, can bo handled safely in the con- V -* structioij phase by following o.stabl ished .. )' recommended work practices. ; 2. If the heal tli facts associated with the us=o of A/C / " pipe can be fill l.v explained in a rational environ- I'-.'. ment, i.e. before hysteria or irrational - prejudice has developed, wc will not`have problems regarding usage, of A/C pipe. . There are three basic spheres of influence we must reach with our educational program to avoid having problems. . A. First sphere of influence. - Those who are directly invoLved, 1. Sales force -' . 2.' Utility managers and their staff. 3. Design engineers A. UtiLitv contractors . 5.- State and Federal, governmental health officials. B. Second sphere of influence - Upper level officials . and the medic.nL fraternity. . ' ' 1. City and County elected officials (Mayors, Super- visors, Counci JLmcn etc.) 2. State Senators and Representatives 3. U.S, Senators and Representatives -- U. Medical officials and doctors. . ' `.y C. Third sphere of influence - The. gcneraL public. It is recognized that the difficulty in delivering our message to each sphere of influence becomes progressively, more complex and expensive as wc expand outward from Sphere PI Our efforts to' date have been primarily to Sphere. i-'L, Our efforts arc now expanding It' try to reach Sphere #2. We have no definite plans to r^ach Sphere i?3, except on" a spot basis, as the cost would reach into the millions of dollars. We therefore recognize we cannot totally contain the problem. CAPCO JEN 0032557 Thru the following -ii*l itplans our efforts to roach Splu't'c -l lias boon reasonably Mica':::; fuL mid has essentially lept our A/C business intact to date. 1. Information' on asbestos and health issue to sales '! force thru: a. Health Fact Bulletins - Sixty bulletins have been issued over the past five years. ; b. Speeches at district sales meetings. c. Travel with sales force in the-field on specific problems. , .--r/.-t -U d. Appointment of, and an oducati'on.. p t*ogram.for, v^"l).i.s t r ici. Ilea l.th Coordi nn tors" ij . ' . 1 2 Coordinated effort with other A/C. pipe producers thru the Association of .A/C Pipe Producers. a. A/C Pipe Producers staff has prime rosponsi.-.' bilitv for programs and contacts with Federal governmental office, and local problems where* - Leval assistance is required. They will.' also 'become involved at the local or state level when specifically requested by member companies b. AACPP staff to maintain a "laundry list" of all Federal. State and l.oca.l problems and , . .update activity of each one on a monthly.- - semi, monthly basis, c. Member companies will handle proprams at ' ; the state and local level, (with the excep tions noteal in a. and keep ACL'PA staff informed of their activities. AACPP Public Affairs Committee I. Regulatory Affairs Program A. ' Economic Impact Analysis of Total or Partial Ban on A/C Pipe ` ` A. D. Little Company" contract B. Risk assessment of substitute pipe, materials. Deferred due to budget .limitations, and an oppportunity r.o secure government generated data on the subject. C. Audit of Asbestos Exposure Levels During Product Life Cycle. ? Deferred. A. I.A. contemplating audit' via EFA ,'TSCA section 8. (a) reporting form. CAPCO JEN 0032558 I. Rej*,u la Cory Affairs Program (Cont'd) * D. Tochnical/Kconomic Fensibi] j.t.v Studies of Reduced Exposure. . . - > E. Medical Evidetvcc/Risk Assessment of Low Level Asbestos Exposure. To be coordinated by Dr. Kotin. F. Retention of Special. Legs.I Council to Monitor State Legislatures Dills.' . II. Public Education Program ' A. Fact Dook/'lnscrts ` r?:- Update "A/C Pipe and Health" and prepare special inserts for a specific audience. (City Council, Water Utility, Medical Croups, General Public etc.) B. Media Backgrounds .. . . Press Kit on .risk/beneCits of A/C pipe. C.. Advertising A/C Pipe safety - Place in magazines .aimed at . Second Sphere of influence, i.e. National City, .Western Ci.t.v etc. D. Audio Visual program update. ': E. Crisis Response and Management information Team. Organize and train a crisis management team to. coordinate industry response to field problems. ' F.. Seminars . Prepare "State, of the Art" medical paper supporting industry positions for direct mail to public officials, present at selected seminars and publish if possible. G. Utility Initiative ' Establish "core market" areas for priority attention Prepare camera ready mailer suitable Cor use by water utilities with field problems. CAPCO JEN 0032559 II. Fublic Education Program (Cnnt'd) 11. Recommended Work Practices Update R.W.P. t:o reflect; recent developments. Develop contractor certi fleet:ion form. . Other .areas where action on asbestos end health is taking place include: A. American Water Works Association . ' .1.' Committee on Use of Asbestos In Utility Construction a. Committee developed a 'recommended work practice manual - Will update ps required 2. Committee to develop an AKWA policy.on asbestos"in' water supply. B. American Society for'Testing Materials 1. . A subcommittee lias been' formed to revise the ASTM-C-50Q Specifications section ."Environmental. Aggressiveness" which dcais with the use of A/C pipe under aggressive water and soi.1 conditions. The objective will, be to clarify the section so. that it will not be interpreted ns being health related. C. A.I.A./H.A. 1. "espouse to A.H.P:R.M.'s from E.P.A..nnd Consumer Products Safety Commission,is being coordinated by AJ.A/WA. The AACPP is cooperating with' AIA/NA ` in this area. . . .. . 2. Revised OSIIA Asbestos Standard. Program is being coordinated by ATA/NA with cooperation of AACPF. - CAPCO JEN 0032560 Recommendations for add i.l: i.ona L act inn.':; - 1. Reestablish an int ordi.vlsionaL asbestos coord inatinr. committee: to provide a means to communicate between: a. b. c. d. e. Asbestos Committee II.S. & i-;. Divisions *' Washington Affairs Office Corporate Relations . ' . '' 2. Establish a team that is prepared to present the asbestos industry,'s. side of the. story .to major industrials who have established a "no asbestos" , . policy, and Co prevent more major industrials .from iioing'so. % v' 3. In order Tor Divisions to develop their individual goals, plans, and strategics fully regarding the asbestos issue, a need exists for the corporation to clearly cominunicare to the Divisions the Corporate goal plans and strategics. 4. Our sales`force is being exposed on a daily basis .to a flood of adverse asbestos articles appearing in the media and are required to defend our asbestos containing products to their customers,eovernmental agencies'and frequently to the community at largo. They do not see our corporation vigorously .defending our asbestos containing products. A more visible defense is required to. maintain employee morale. i CAPCO JEN 0032561