Document eQLDOJkj0B9jpL4JZvrZzB5e

FILE NAME: Union Carbide (UC) DATE: 1975 Sept 25 DOC#: UC235 DOCUMENT DESCRIPTION: Presentation to Erie County Air Pollution Control Division by the Marking Manager for Union Carbide's Asbestos Products PRESENTATION Tfl _ER,IE COUNTY AIR POLLUTION OQNTROL DIVTSTav September 25, 1975 My name 1s John L. yens. I am Marketing Ha,,ager fQp U n j m Carbf<Je,5 ? products with offices in Niagara a n , . N.Y. I have been involved with Union Carbide's asbestos business since 19SS; and, since 1972 ,,hen the OSHA {Occupa tional Safety and Health Administration-Department of Labor) asbestos standards were published, I have also been heavily Involved with federal, state, and local regulatory activities concerning asbestos. He presented testimony at the OSHA hearings on the asbestos standard in 1972; and I served as an industry representative on a committee to develop the federal EPA {Environmental Protection Agency) asbestos standards, which were promulgated in 1973. Asbestos standards are now being developed especially for the construction industry and I attended and presented testimony at a two-day hearing in Washington last week. ' lith me tonight is Dr. H.B. Rhodes, my Technology Manager. One of his main responsibilities is to supervise the air monitoring service which we offer to our customers. Or. Rhodes is chairman-elect of the technical sub-conmittee of the Asbestos Information Association and is also actively engaged in the asbestos/health question and regulatory activities. He attended a symposium in England last week 'on asbestos and health and is preparing an article for publica tion on the health hazards of asbestos in certain segments of the construction industry. His training in air sampling and analysis was obtained at special courses offered by NIOSH (National Institute for Occupational Safety and HealthDepartment of Health, Education and Welfare). Or. Rhodes has also performed extensive air sampling in connection with the use of asbestos in various compounds A08792 which are sc rayed on surfaces -* .,,P -Ms ,,as relatively low levels of asbestos can b* " ' ^ done lf H * t0 substantiate our position nany proSiJc;s which, upon th>soray- 91 C3USe a"y SiSn,fiCant f a^ o s * t . At your discretion we can send this supporting information to you i,, t!l8 ,,8xt severa, day$ ' Union Carbide is engaged the mining end ,, ,, i n , of asbestos fibers at its SP *" ^allf0'"n,a* and "* market aad t o s fibers throughout the world. We supply asbestos as a raw material ,, , . e lal to compounders or manufacturers of various products, some of which are sDraved u* * P Sy6d- We d0 "ot s"PP'y asbestos for use in sorav p r o o f i n g or insulation materials: and, in f,ct, nefther ^ " Asbestos has e s s e n t i a l baen eliminated from such products because of the attendant potential hazard tcoo wwoorrKkeerrs aann/di +tth.e general, public. Our interest in regulatory actions is to prevent anb,.gUity and tD ^ promulgation of standards which are difficult or impossible to enforce because Of their generality. We want to assist in the development of standards which eliminate or m i n i m i asbestos exposure, but which do not effect an unnecessary pro ibnion against the genera, use of asbestos, especially i,, products which present no ultimate hazard to the general public. Following are some excerpted quotes from e 197, report of the National Research Council: "At prasent, there " eVide"Ce th" thS * " > found in most members of the general population affect health or longevity....Asbestos is too important in our technology and economy for its essentia, use to be stopped.... Continued use At minima, rish to the public reguires that the major sources of ma,,-TMde asbestos emission into the atmosphere be defined and controlled." would agree that these c o u n t s are closely ,, ,, n e d with mine. I think you It is my understanding that you are considering legislation with the following wording: "No person she,, cause, suffer, p e m i t , or allow surface coating by th. spraying of asbestos or asbestos-containing materials." The spraying of asbestoscontaining materials has received substantia, publicity as a health hazard, 08793  P n - n i y as the r ^ n of th. extensive use s=rayai 3radliet, fo. , and insulation. Industry, ^,yprr,--,,.snn*i, a.nd. , , sroups ^ recomj2^ sK.oo. >ng P" Ct,Ca' "h,Ch i"V0,i2d "*t t n a '* " " ^ i n g to 80S asbestos l)ith Of 00 p e n d e n t hinder, was hazardous; and jt ^ ^ " ' SU?P rted ^ the d 3 U - . that materials ^ safely S m a n ,Uant,t,eS f " h" " 5 and Suitab,e *< can be sprayed safely end ,n compliance with existing federal standards we are strongly , favor of ,egfs,a on which woold prohibit the spraying of asbestos-containing materials for firpnmne* v<e.kl ,, "reproofing and insulation which generate which 8 hSt em'" i0"S ha2aM0US t0 " * P U b H C emfr0nrent- the wording h yoo have proposed woold inadvertently, prohibit the spraying of asbestos- containing materials even though they generate no asbestos dost. These appllca- ions would include automobile undercoating, roof coating, textured oaints airplane de-icing, and many others which . I d adversely affect activities' involving thousands of jobs in Erie County. We therefore propose the following revised wording for your legislation0 person she,, cause, suffer, perait, or allow visible emissions of asbestos dust from the spraying of asbestos-containing materials used for fireproofing and insulation." we are confident that the above wording will accomplish your purpose, and ours; and that the safety and health of the genera, public wil, not be compromised or impaired by this revision. Thank you for your time and attention. John L. Myers Union Carbide Corporation Metals Division 08794