Document dapD97JQVJJGap6Dd7KDaNMLe

T April 23, 1975 Mr. R. T. Monagcm, President California Manufacturers AnocIaMon P. O. Bax 1138 Sacramento, California 95814 Dear Bob: Enclosed Is a draft of a letter which 1 suggest that CMA might wish to send to Senator Marks as a follow up to our recent conversations with him. I would also suggest that Eddie Star/ of the Asbestos Workers Union In San Francisco, Local 16, also be copied since he received a cop/ of Dr* Sellkoff's Mo/ 14th letter to Senator Marks. Feel free to exorcise whatever editorial license you feel Is appropriate and thanks for the help. Very truly yours. WCTies Enclosure cc: Mesors. N. F. MoAarfi W. C. Thurfaer UCC 009998 Draft - April 23, 1975 Senator Milton Marks California State Senate Dear Senator Marks: It was a pleasure meeting with you last week and having the opportunity to discuss proposed amend ments to 5B24I9 relating to the spraying of materials containing asbestos. In the interim since our meeting, we have had the opportunity to review Dr. Selikoff's letter of March 14, 1975, to you and would like to provide some comments on the questions raised by Dr. Selikoff. Dr. Selikoff apparently did not receive the detailed dust count data which CMA submitted in support of the proposed amendments and thus is quite correct in theposition that the information available was not adequate to evaluate the proposed amendments. It seems from the nature of his other questions that he is looking at this in the same light as the now discontinued operation of spraying asbestos building insulation. In insulation spraying, bags of raw asbestos fiber are mixed in a water slurry and sprayed on to steelwork and other surfaces for fireproofing. There is little or no permanent binder so the sprayed material ends up as a mater of virtually pure asbestos held in place by its own entangled fibers. Such operations obviously represent an in appropriate use of asbestos and have been outlawed. There is a substantial difference between this spraying of asbestos for building insulation and the operations covered by our proposed amendments wherein a relatively small amount of asbestos is added to a liquid binder for control of certain physical properties of the material. The as bestos in the finished coating or item is firmly held in a permanent binder. Recognition of these distinctions is essential For an appropriate evaluation of the proposed amendments. Referring to Dr. Selikoff's five specific questions, the following comments are offered: 1. All of the systems except the interior wall and ceiling texture sprays i.e. water-based systems with water soluble binders, are factory mixed and de- UCC 009999 r livered to the spraying location with the asbestos fully wetted out. The tex ture sprays, containing 1-3% asbestos mixed Into the other dry Ingredients are typically added to water at the site. The act of dumping is controlled by the OSHA regulations and if it cannot be done in compliance the entire opera tion should be stopped. There are moves at some locations to compound this type of spray at factory locations and pump it directly into the sprayer's tank. 2. Extensive supporting data have been supplied on this point. (See Tables l-IV attached) The maximum level found was a ceiling concentration of 1.6 fibers/cc with values of several tenths of a cc most typical. It should also be noted that in most of these counts all particles longer than 5aj wi th L/D y 3 that in the judgment of an experienced operator could possibly be asbestos were counted as such. This tended to include a proportion of particles that were not really asbestos. 3. Regarding contamination of adjacent surfaces during spraying, it should be stressed that the materials sprayed are being used in the finishing or as the finish for surfaces and parts. Where overspray occurs, it is normally removed immedi ately or covered with subsequent coatings. Where it is not removed, the binder sets and holds the asbestos. There are no dry clumps of unbound asbestos as could occur with the insulation spraying and which seerns to be of particular concern to Dr. Selikoff. We are prepared to provide an application by appli cation commentary for the systems tested in developing the supporting data if it will be useful. UCC 010000 r- 4. Regarding subsequent manipulation of the coated surfaces, the texture sprays (Table I) the wall and roof sprays, (Table II) and the asphaltic roof and under coats (Table IV) are finished as applied and are not sanded or worked further to any extent. Certain of the resin applications (Table 111) are cut, sanded or ground after the binder resin has hardened. A substantial amcunt of fiber . i-T count data has been obtained for this type of operation and wets provided In Tables V and VI. The highest level found In a commercial situation was 0.4 fibers/cc. In a laboratory test in a small closed room the maximum was 1.2 fibers/cc. 5. Regarding contamination of the workplace by waste materials. It should be noted that these materials cure or harden when used so the asbestos Is bound in. An exception to this is the "empty" bags for the interior wall and ceiling texture sprays. These do present a potential exposure but are rigidly controlled by both the Federal and California OSHA regulations. It should also be noted that the removal of overspray on the floor is required after some texturing opera tions. This is normally done wet with a scraper and the floor is then finished. We would like to reiterate that the proposed exemptions of certain additional ques tions from SB24I9: 1. Can be accomplished within existing OSHA and EPA regulations; 2. Will generate very low levels of airborne asbestos contamination and that these dust levels are similar to those of already exempted operations; 3. Will insure the continuing economic well-being of those companies and workers in operations proposed for exemption. UCC 010001 r- Your continuing consideration of this matter is appreciated. Very truly yours. Attachments cc: Mr. E. H. Story - Local 16 AFL-CIO 2601 Mission Street - Room 707 San Francisco, California 94110 R. T. Monagan, President California Manufacturers Associati UCC 010002 w*Tfa-BA$co systems VITH VATEB-SOLUSLE 81N0CKS Si^le rw*< | cnation Comerclal Ai 31 icatlon I . IKTERtOR TEXTURE '?WS 12 Celling spray. Sate 6/14/73 Binder Ijprm-^^ Irate Ht. J Asbestos Spray Gun Tvpe Soya protein. 2 Air supported 82 a2 a 3 Hill spray. a Starch. 2 a 35 ' a ' ' 2' a 38 Celling spray. -' a 28 * 56 m a 131 Hill spray. - 102 a a 1a 1 1' 2 ^a 2 Operation Sample Ttme (Win,] Asbestos AirPcrrv; Cor.centr*: (Ficers/cc Operator applying celling spray to condominium apts. Operator wiping walls after ceiling spray. . Operator applying wall spray to condominium apts. Operator carrying hose during wall spraying. 71 68 51 34 Operator spraying celling of condominium. a ' 14 IS 15 Operator spraying vails of condominium. a^ 21 12 0.1 0.1 0.3. 0.8 0.1 0.5 0.6 -1.6 1.1 8-38-2 8-2 1-25 2-49 2-54 Celling spray .a Vail spray. 10/3/74 * a- a aa a aa Celling spray. a 12/4/73. a -1 1 2.5 2.5 1 1 a a a. Operator applying celling spray to home. . Operator "wiping" walls ifter celling spray. Operator applying wall Spray to home. full coverage. Operator spraying glitter. Immediately after ceiling Sprayed. 19 22 24 26 Operator applying ceiling spray to condominium apts. , Operator *Vip-frtg* walls fUr ceiling spray. 20 24 0.5 0.2 0.07 0.0 0.5 0.1 ^ Sited on total fors-.ulatlon as sprayed* * .;JUHIUU'|>*|.IVL:' * SJ!UJIll*gPVl apn'.L 4'1 W UCC 010003 r I. Water-Based Systems .wi th VJater-Solubl e Binders Binders: ' . Type: Starch, polyvinyl alcohol, soya protein, or equivalent. Content: Typically 6-8% by weight of the dry formulation before mixing with water, . 2-4% as sprayed. Main Uses: Interior wall and ceiling texture sprays. (Where texture is applied to walls it must be . covered with at least one coat of a latex or oil-based paint.) . Asbestos Content: Up to 3% by weight of the total formulation as sprayed. Supporting Data: Table I. UCC 010004 v*m-Msco V*" VtTMUTC* Sipl Oesfp-at'On Commercial Apo 1 f eat ion | - IITEH10* C0iriN;S -< Vail end Hoof ' Sprat. J-J e-j M Date 10/4/7^ ' W K` Poof spray. S/J0/7A Binder Approx-W . Intt Ift. * Asbestos Spray Cun Tvpe Vinyl latex. . Acrylic latex J.7 Air supported. 2.8 * 0 Acrylic latex. ? Airless. K-K3 *. M `M 0.7 M * OperatIon Sample Tire (Kin.) Airborne Aabes to* Ccncen r rat ion (Fifcers/ee.'v1*' Operator spraying vertical wa!1 panel .H m IS 12 t Operator spraying downward onto a targe roof. M 28 U 0.0 0.2 0.2 0.0 0.0 (1) Itscd on total formulation as sprayed* t npm UCC 010005 Mm.WaH1*) ' Avy II. Water-Based Systems with Latex Binders Binders: Type: Vinyl latex, acrylic latex, vinyl-acrylic latex, or equivalent. Content: Polymer content of 10-20% by weight as sprayed. Main Uses: Exterior coatings for buildings and mobil homes, including roofs. , Asbestos Range: Up to 4% by weight of the total formulation as sprayed. Supporting Data: Table II. ] t . i ji, UCC 010006 mu m RESlN-BkUO SYSTEMS Sample fjgsIcnitloH Commercial' A;pl i cat! on Bate 1 - POlTESTfR MSt`;S A. General Purpose Laminating Resins (9 Boat manufacture. 12/7/72 ' . Binder Approx-^ Iwte Vt. * Asbestos Spray Cun Type General purpose laminating resin. O.S Air-supported (hopper, . Ooeratlon Operator spraying nolds wit's resin 1 chopped glass. Sample Tine (Win.)' Asbestos Alrt.'rn Conccrirr (Fibers'cc .24 1-13 l- 1-30 ' 10/31/74- `1 ' 0.5 O.S O.S R-34 10/8/74 B-40 . M2 ' *m m B. Chemical Resistant Resins J-21 Fiber-glass pipe manufacture. ' 8/13/74 R-26 0.5 ' * O.S 0.5 Chemical resistant resin. . 1.4 ' 1.4 Operator spraying resin 5 cropped fiberglass. (Includes roll-out time.) Operator spraying resin & cropped fiber glass. Operator spraying resin 4 cropped fiber glass. m m. Operator spraying mold with resin. (No glass-.) ' 16 .5 4` 55 S3 35 0.1 0.4 0.4 0 0.03 0.1 Airless. 'm * Operator adjacent to automatic spray machine coating . 23* mandrels. Operator wiping mandrels. In area near spraying. 23 0.1 14 0.4 J-S Ship coating. 10/3/74 Chemical 0.7 Air-supported Roll-out man. In 6$ 0.4 resistant wand. spraying area about resin chopped 1/4 of time. fiber glass. 3-7 % '* 0.7 Operator spraying 41 0.4 Ship hull in Cry dock. H-28 *.7 - 23 0 0. ) Based on total fonmalation as sprayed. UCC 010007 TA3U IH fcon; I-^Cd7 AES1H bases systems Sample IVeJc'iation Cormercial Aooltcatlen tl - EPOSY Rjsrvs a. mied e ro*v K>3 Ship coating. R-10 K-10 * * 1*27 J-1 Date 10/2/74 . Binder Approx- 1 irate 1ft. I Asbestos Soray Gun Type Epoxy prlmen High build epoxy. ( l.S Airless. 1.5 0 v p. 0 Air supported. 'a a' Operation Operator spraying outside A under a Ship. 'a Operator spraying side of ship from Scaffold. a '. a Sample Tire {Win.) Asbes: AirtcConctn;- f F i ie rzu 33 < 31 ' .K 60 . 0.2 0.2 0.1 0.3 o.o: ' 3. Epoxy - Coal Tar K-45 Coating dry dock. 10/1/74 Epoxy Coal-ta^ solvent. 1 K-l - ' *, (t-J Coating pipe It Interiors. HI - AtKYD SSSI'I PAINT . H-7 Painting 10/6/74 building exterior. H-35 * -- ` -. - . Alkyd resin. 1 12 12 % Airless. ' a Air-supported wand. . . Operator spraying Side of dry dock from suspended platform. . Operator spraying side of dry dock from fixed scaffold. Operator spraying Interior of 3", S' and 12* diameter pipe. Airless gun. a. Operator spraying building exterior ` wall. a 11 36 37 9 S 0.2 0 0.1 0 O.Ot 01 Based on total formulation as sprayed. '` , UCC 010008 Binders: Type: Polyester resins, alkyd resins, epoxy resin alone or in combination with coal tar or equivalent resin. Content: Range from~6% in zinc-rich primer to~.49% for heavily filled alkyd to 99+ for polyester laminating resins. Main Uses: Fiber glass reinforced boats, pipes, shower stalls, and similar articles. . Maintenance coatings for steel and concrete. Intumescent and zinc-rich paint. . Exterior alkyd paints. '; Asbestos Range: Up to 12% by weight of the total formulation as sprayed. .. Supporting Data: Table III. UCC 010009 TAHt IV ASPHALT IC AND COAl-TAR 8ASC0 SYSTEMS Si^lt Identl flcatlon K-12 *-J1 a a 3 3 - - CormercTal Xpp1icat 1 on Oate Auto undercoating .io/7* {Sotaid deadener) 'H M fibrated Roof Coating, 9/26/7* Binder Cut back asphalt m H N io/i 1/7* a 3/26/7* M 10/11/7* Emulsified 12/18/74 asphalt fibrated roof coating. . M It M Steam refined, emulsified asphalt. Approxirate 4*t. I Asbestos 15 15 < Spray Cun Tyce AI rU. 81 Air supported . IM 8 Airless 8M 3 Air supported 3 . Airless Operation Operator spraying on auto body. M Operator spraying against vertical Steel surface. M II m WM Operator spraying against vertical steel surface. m Saiplc Tine (Hin.) 7 6 - - 43 ' 23 Al rbome Asbestos Concemrat i on (r - ben/cc > 0.2 1.5 0.02 0.11 0.03 0.07 0.16 0.17 h) Based on total formulation as sprayed. \ ptllilDJUP.iin" ~ ' i m 1 ij! mi" W'1.11 jp'LIU'iMPW'MUjipBm am. Il MMium UCC 010010 iv. aspuaiuc and Loal-iar Based Systems -.Binders: . Type: Cutback and emulsified asphalt and coal-tar materials or equivalent. . Content: Typically~'45%. Main Uses: Automotive undercoating and sound deadener, roof coatings, foundation coatings. Asbestos Content: Up to-152. . Supporting Data: Table IV. . - .. I '< MPTOi UCC 010011 * IW UI|^H!J,H.-I W * JUJu WRf f AIRCOPSC AlftSTOS fl6C CO'.NTS CmMDW. ?o jtfQ'f:.'. rr acin-casth srrr-s ccnimhhC ^tlanitlen Csnnerel*! Acollcatlcn 1. TK'WSrr R'S!'I .(Polyester) - folding furniture perts * m Date 3/15/72 Resin Polyester 1929-40-4 m 12/6/72 m Asbestos ApprQ*. Tyne ut. Z Operation Sample Time (H1".l Airborne Astestos Fiber Concentration (Fibers/cc >i.i 8G-244 . 0.05 0.05 m 0.3 Operator hand sanding snail parts. Operator running power sender with Integral hood. Operator sanding and grinding molded darts. Good hood 4 .emulating System on grinder. 45 45 23 0.002 0.002 0.3 1929-82-3 1929-82-4 1929-82-5 M3 M Fabrication of reinforced fiter glass pipe. ' ' - 2/27/73 Polyester RG-144 2-3 m m 8/13/74 - ' 2-3 2-3 tS-244 1.4 . 1.4 Operator pulls pipe along line. Saws off nd with circular saw. 19 Same operation as 1929 82-3. 49 Operator removing end of 45 pipe with scarfing macnine. Operator shaping end of pipe with.bell 4 spigot machine. Operator cutting off pipe end and light erinding ea exterior surface. 16 17 0.1 0.1 0.04 0.3 0.2 1-26 8-8 1-39 Fabrication of FRP tanks ar.d pipe. 8/13/74 ` * Polyester . RG-244 1.5 1.S 1.5 Operator grinding Inside of 13' l.D. x 261 tank. Continuation of same operation as 1-2S. . Operator grinding edges 'of miscellaneous small parts. 16 5 25 0.4 0.3 0.3 1929-84-4 1929-84-$ Production of artificial bricks. * 3/8/73 Polyester ' RS-244 2.0 2.0 Operator cutting with sabre saw. Operator tricning with sabre saw. 44 39 0.1 0.2 8-20 Production of fiber (list boats. 8-25 11/26/74 Polyester ' . RG-244* 0.5 0.5 Operator grinding Inside of boat hull. 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