Document dYdj1EpB6eggxkM43Y0ja4ONB
Friction materials standards institute, inc., east 210 route 4, paramus, nj 07652
BULLETIN
NO, 7 5 9
April 28, 1983
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) PLANS TO ACCELERATE SCHEDULE FOR REVISION OF PERMISSIBLE EXPOSURE LIMIT FOR ASBESTOS
We are enclosing copies of article notices and correspondence relating to OSHA's recently announced plans to accelerate its schedule for revision of the asbestos standard. Specifically, OSliA intends to publish a notice in late May or early June to hold hearings on revision of the OSSA asbestos standard.
While the hearings will be extensive in scope, two important Intentions of the hearings will be:
(1) A review of OSHA's Notice of Proposed Rulemaking of October 9, 1975 with emphasis on reduction of the permissible exposure level (PEL) to airborne concentrations of asbestos fibers from 2 fibers per cc to 0.5 fibers per cc, 8 hour time weighted average (TWA). The peak or ceiling concentration would also be reduced. In addition, other items in the October 9, 1975 notice will be updated.
(2) Expansion of the scope of the October 9, 1975 notice to include the construction industry as well as manufacturers of asbestos products. (The original October 1975 notice did not apply to the construction industry.)
Our enclosures on OSHA's plans for revision of the asbestos standard do not include the correspondence between Mr. Auchter, Assistant Secretary for Occupational Safety and Health and individuals of the AFL-CIO. The enclosures with this Bulletin are as follows:
1. April 8, 1983 article in the NEW YORK TIMES.
2. Asbestos Information Association (AIA) Notice of April 14, 1983 to its Members concerning OSHA's plans to accelerate the schedule for revision of the asbestos standard.
3. Letter from Mr. Bob Pigg of AIA to Mr. Thorne Auchter of OSHA concerning this proposed new schedule for revision of the asbestos standard.
4. Draft copy of letter suggested by the AIA to concerned parties' Congressmen on these proposed changes.
FMSI-0385
FMSI02646
OSHA
-2- April 2d, 1983
This package of information was sent to the Institute by the AIA. They would most obviously welcome support of correspondence to individual Congressmen. Without elaborating on the problems of acceleration of changes to the asbestos standard, there are several considerations which apply to any such changes.
Expansion of the standard to the construction Industry which has the greatest nuinber of workers exposed to asbestos will delay establishment of a more appropriate work practices related standard for that industry. The con struction Industry differs from the much smaller asbestos products manu facturing industry because of the smaller number of employees per employer, the transient nature of the work force, and the lack of a fixed site in cluding the problem of outdoor work. The preferred approach for control of asbestos would be to first establish a standard for the larger con struction Industry before zeroing in once more on the asbestos product Indus try.
Also of concern is the difficulty in reproducing asbestos fiber counts by the membrane filter method when the counts are in the 1 fiber per cc range. AIA particularly noted the difficulty in reliably measuring lew concentra tions of asbestos based on a round robin study of the membrane filter method among its Members.
Another consideration is that Great Britain, which pioneered in studies and regulation of asbestos in the workplace, has a 1.0 fiber per cc PEL for chrysotile asbestos. Great Britain and the Province of Ontario are making ongoing assessments of asbestos exposure, and their reports on these studies should be available in the Summer of 1983, The results of such assessments would certainly be of help to OSHA in its considerations of any amendments to the TEL.
Theforegoing information and comments are sent to the Members for its information and consideration. If one is to write ones Congressman, it is suggested that the "Draft" letter be modified to reflect the writer's specific concerns applicable to its facility.
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Copies: Delegates and Alternates H. E. A. Committee Active Members - List B Licensees (U. S.)
E. W. Drislane Executive Secretary
FMSI 02647