Document emak236Ldq7d3vYL6kzQozKLM

FILE NAME Manville JMA DATE 1977 DOC JMA115 DOCUMENT DESCRIPTION British Occupational Hygiene Society Asbestos Committee - Meeting Minutes Letters & Memo 1977 British Occupational Hygience Society Asbestos Committee Documents form J. Marsh R.M and Cape describe dissention within British Occupational Hygiene Society BOHS asbestos standards subcommittee with industry members preventing the group from recommending a lowering of exposures by more than half from 2 cc to 0.9 100 yrs to 43 Lewinsohn R.M. letter 6/1/77 to BOHS group critical of US asbestos industry compared with UK industry p..3 of attachment -, INTERINTERINTER INTER ORGANIZATION COMMUNICATICOMMOUNICANTION Maybestos MaybesMtoasybestos Manhattan Manhatan Corporate Trumbull DIVISION " " " LOCATION TO AIA EXECUTIVE COMMITTEE 9.) ~ oo 00024200 02420 DATE February 7 1977 SUBJECT Executive Committee Meeting International Asbestos Information London - February 1 1977 Conference PRESENT Mr. Mr. Dr. Mr. Dr. Mr. Mr. Dr. Mr. Alexandre Angelotti Costa Cross Gaze Marsh Piuze Robock Van der Rest - France - Italy - Italy - Director General - U.K. Presiding - U.S.A. - Canada - Germany - Benelux 1, z! ORGANIZATION The duties of the Director General a draft having been circulated previously by Dr. Gaze were agreed upon Although the title Director General was considered a bit pretentious it was retained because alternatives such as Executive Secretary do not carry the appropriate connotation in some translations A minimum budget of 44,200 was approved with the understanding it would probably be found to be inadequate Suitable quarters for the Secretariat have been located nearby the Cape office Mr. Van der Rest suggested and the Committee agreed that a lease be negotiated and the Secretariat be staffed as soon as _ possible Initially the Secretariat will consist of a secretary and the time services of Mr. Cross Dr. Gaze explained that Cape had had difficulty in locating a replacement for Mr. Cross and were not able to relieve him of his responsibilities at Cape as early as had been anticipated Member Associations will upon Bank be billed according to the attached schedule as in Hamburg and the funds will be deposited in a Account agreed Swiss - N break February 7 1977 CURRENT DEVELOPMENTS OUTSIDE THE U.S.A. Dr. Gaze asked each member present to comment on the present situation in his country The present situation in the United Kingdom is extremely delicate The Government Advisory Committee on Asbestos established in May 1976 the risks has just issued a short interim from asbestos in perspective in statemen tt o put the light of present knowledge Although the Committee does not recommend at this time a change in the standard the following excerpts indication from the report give a clear the majority of the thinking of Exposure to all forms of asbestos dust should be reduced to the minimum reasonably practical In issuing that there this statement are a number of to be investigated further definite recommendations the Committee emphasizes topics which will have before it can offer These topics are a the ingestion of asbestos b response relationships for various diseases c asbestos waste disposal a asbestos in the general environment e the substitution of safe or less hazardous substances for asbestos em, The BOHS Asbestos Committee agreement concerning a revision has not been able in the standard to come to The Chairman Gilson has resigned industry representatives on the e Committee are in favor of reducing the present exposure limits from 100 fibre years to 43 fibre years Industry members are not in agreement and dispute the statistics on which the proposed standard is based Dr. Gaze believes industry must take some initiative to resolve the deadlock Dr. David Muir of the University of Edinburgh has been commissioned to study the statistics and give industry his opinion Italy as yet has present national no official regulations labor contract there is However in a provision the limit- ing exposure to 5 fibres as is the case in mining operations in Quebec The next national contract may specify a lower level According to Mr. Angelotti data compiled by Dr. Vigliani show no excess of lung cancer among miners In Germany a new MAC Maximum Allowable Concentration list has just been published and within the next two to three 3- February 7 1977 months limits will be translated for chrysotile and into law The permissible exposure amosite asbestos are 2 fibres and relate only to fine respirable standard is also being developed A been made with respect to a standard dusts A gravimetric decision has not yet for exposure to crocidolite Dr. Robock stated that in Germany only 10 of asbestosis cases The why difference U.K. lead to lung cancer as contrasted with 50 to 60 in the question is the U.K. . Mr. Piuze reported that Quebec miners are finding it easier to meet the present gravimetric standard Mr. Hutchison was not able to be present because of the current uproar over the Quebec government's proposal to take over or acquire a substantial interest in mining operations He also reported measurements of ambient air concentrations in the town of Thetford varied from 0.02 to 0.06 fibres Presumably this represents the concentrations to which the general public has been of value exposed to for many years and the information may be in estimating the biological effects of occupational exposure At one point last year the government in Holland was on the point of prohibiting any use of asbestos without special permission Due to the intervention of industry representatives including Mr. is limited to Van der Rest the ban without special permission crocidolite and sprayed asbestos All other uses of asbestos will be held to a maximum not TWA exposure of 2.0 fibres It is expected that Belgium will shortly have regulations limiting exposure to 2 fibres TWA without any exceptions for crocidolite France as yet has no regulations It is expected that recommendations will be made sometime this year The industry has mounted an extensive information campaign to offset the negative reports that have been widely circulated Following a meeting last December at the International Center for Cancer Research at Lyon Dr. Selikoff called a press conference which according to Mr. Alexandre had a very bad effect At the press conference Selikoff announced the intention of NIOSH to recommend to OSHA that the U.S. asbestos standard be lowered to 0.1 fibres WORK OF THE COMMITTEE The Committee reviewed and the Secretariat attached conference approved the program of work for first proposed at the Hamburg Dr. Gaze stated that he Secretariat shoulbde to believed collect the first priority of the edit and distribute to the a -~ 4 - February 7 1977 Member Associations information on asbestos and health It was agreed that in order to expedite the distribution of such information during the interim period when Mr. Cross services will be available only on a part basis Executive Committee members will distribute to each other as well as to Mr. Cross any pertinent information which comes to their attention With respect to future operations of the Secretariat Dr. Gaze stated he felt that any attempt to conduct public relations activities should be avoided at this time and that the Secretariat and the Executive Committee should concentrate _ - on matters of practical and immediate value In this connection certain assignments were given to members of the Committee and others BT ' Medical Scientific Advisory Committee - It was suggested that either Dr. Wright or Dr. Kotin be asked to chair such a Committee Dr. Gaze will take this up with Manville Bag Opening Methods - Mr. best available methods Piuze will provide information on Fiber Packaging Shipping and Waste Disposal Including Disposal of Bags - Mr. Dorner and Mr. Angelotti Asbestos Cement Processing - Mr. Alexandre Asbestos Textile Processing - Mr. Verrill Use and Handling of Asbestos Containing Friction Materials - Mr. Marsh International Standards or Codes of Without Regulations - Dr. Robock Practice ea EUROPEAN ECONOMIC COMMUNITY for Countries A detailed communication attached concerning the objective evaluation of the risk to human health caused by asbestos has been circulated by the EEC to various European industrial societies for comment It was agreed that Mr. Cross Dr. Robock will represent the Executive Committee in , and dealings with the EEC office ACTIVITIES OF ORGANIZED LABOR A representative of the International Metal Workers Federation attended the IAIC Conference in Hamburg last November There appears to up at Oslo be an opportunity to revise the resolution last August a 0.1 fibre limitation taken It has been suggested that it would be useful to have a meeting of - 5 - February 7 1977 four or five representatives from the IMF and four or five from the Executive Committee to review responsible scientific papers and come to a pragmatic solution with respect to exposure levels Charles Levinson Secretary General of the Federation of Chemical and General Workers members has come down to issued a zero a document calling exposure level for International Union 7 million the industry to oo In December the Trades Union Congress U.K. recommended to the Government Advisory Committee on Asbestos that exposure levels be reduced to a 0.2 fibres level and that the use of asbestos be banned entirely within 10 years This was done without consulting some of the member unions including the Transport and General Workers Union which is not in favor of such a recommendation SUMMARY _ It is now clear to those who have followed events that the asbestos industry internationalliys literally engaged in struggle for concern with survival potential Recent developmentasn increasing environmental hazards i.e. risk to the general public and association with cancer and mesothelioma the problem have greatly cancers other increased the than lung scope of Those seeking to ban the use of regulations which for technical asbestos altogether or impose or economic reasons would have the same effect are extremely vocal and powerful and command the attention of the news media and the politicians The crux of the matter is that science to establish a level of exposure below has not yet been able which disease will not occur Insufficient time has lapsed to permit epidemiological studies of occupational groups working under modern well controled conditions In such circumstances we are confronted with a political issue in which technical and economic issues are secondary If the industry is to survive exposure levels and use of asbestos and asbestos products must in the processing be reduced to the lowest possible arbitrary numerical of achievement regardless of any limits and scientific studies to existing determine more accurately the level of risk must be strongly supported The final worth the question will be whether the benefits of risk entailed in its handling and use asbestos are as attachments John H. Marsh Forecast of Expenditures Duties of the Director Communication Re Pollution by Asbestos to EEC Member States 9 8 = Industries Cape IndustriIndustries es Limited ZAOAY 114 Park Street London W1Y 4AB Telephone 01 402 6022. Telex 24811 Telegrams Inrenupt London Bars ern A glaon Registered as above Mr. M. Harris Johns Manville Corporation P.O. Box 5108 Denver Colorado 80217 21st March 1977 ae te Dear Moke esSN i have to acknowledge your cable concerning Dr. Kotin and your letter of 2nd March I do agree that it is of primary importance to bring all your forces se to hear in countering the effect of the NIOSH submission and I am indeed obtenr grateful for available your offer to make George Wright and Dr. Felnar's information I Walter am also Smither appreciative of your suggestion that to Read the Medical Committee of the we should get International Asbestos Information Conference but I am somewhat reluctant to do this since both Alex Cross and I are already taking prominent and one more Cape man would I think be a bit parts in the organisation too much I am therefore proposing that we ask Dr. Robert Murray to lead this team and to set it up in the first place with the specific task of collecting information enen asbestos disease from all countries throughout the world If this works well we would consider a more formal appointment of a medical advisory committee headed by Dr. Murray am not sure whether you know Dr. Murray He was with the International Labour for the Trades Union Organisation and Congress in this subsequently was Medical Advisor country from which he retired in 1975. Although of course he is not connected with the Industry he is I believe an entirely suitable person for this task and I am putting the suggestiotno the Executive Committee members Our main concern here recently has been with the recommendation of the committee of the British Occupational Hygiene Society which has been reviewing the fibre standard You will remember that it was their original recommendation that resulted in the British fibre standard evidence being based on the health record of a number of employees at Turner's textile factory in Rochdale whose record could be set against known dust levels the te te 12 This committee has produced a draft fibre standard The Industry based refused to accept this conclusion and so without agreeing on a recommendation report with a recommendation for members of the committee however the committee has fallen apart The reason for this disagreement is that the 0.9 figure hinges upon the incidence of erepitations in some eighty of the men who were exposed and this is to some degree supported by parallel data involving ray changes and what is described as suspect asbestosis It is the crepitation data however which is the most important and which is hotly contested by Turner's who point out that there is not sufficient agreement on the numbers in which crepitations have been diagnosed and that examination indicates that members of the many of these people committee argue that are now free crepitations from come crepitations and go whereas Some Walter Smither argues that such crepitations associated with asbestosis are quite distinctive and that they are permanent A good deal depends upon how this disagreement is resolved It had been my intention to send you a confidential copy of the draft report with this letter since I would have much valued your comments Ceorge Wright's and Paul Kotin's on the document I had a letter from George this morning however and he tells me that he will be in the UK next week and so I propose to hand it to him personally The facts as distinct from the recommendation are to be written up and then sent as evidence to the Advisory Committee on Asbestos that has been set up by the Government and it will be this committee's task to advise a new standard The Industry is therefore very concerned to make a further submission to the Advisory Committee setting out its criticism of the statistical interpretation and possibly putting in a recalculation Aside from this we are much occupied with the European Economic Community who are taking an increasing interest producing regulations and guide lines involving asbestos and also with international trade union organisations In view of all these uncertainties I do understand that you would not be in a position to think about any collaboration in South Africa It would be nice to think that the situation may reach a point within the next twelve months when you might view things differently - but in any event my invitation to you to visit our mining operations still stands Aside from all these problems I do hope that all is well with you and yours Yours ever bee nerar Dr. R. Caze RG WFG 000918A 000918A FyKick Raybestosie Manhattan CORPORATE CORPORATE HEADQUARTERS 100 OAKVIEW DRIVE TAUMBULL CONNECTICUT 06611 U.S.A. 203 371-010 HILTON C. LEWINSOHN MB BCh D.I.H. CORPORATE MEDICAL DIRECTOR June 1 1977 Dr. S. A. Roach Imperial Chemical Industries Central Medical Group South Lodge P.O. Box 3 Fulshaw Hall Wilmslow Cheshire SK9 1QB England U.K. Ltd. Dear Stan I am afraid that it is impossible to condense the American position into 300 words I have attempted to outline the various features contributing towards the complex situation in this country and have relied heavily upon information supplied to me by Richard P. Carter of Manville Corporation The opinions expressed in the accompanying note are mine I hope you find the information of use to you although I cannot see how it will influence the derivation of a BOHS Standard from medical and dust sampling records other than to stress the very real politico implications of any proposed standard The ultimate decision is with government agencies and the politicians the facts having been put before them Yours sincerely Hel^n Hell^n Hilton C. Lewinsohn as Enclosure CC Mr. R. P. Carter... Mr. J. H. Marsh > > "D NOTE ON THE AMERICAN POSITION ON ASBESTOS HEALTH STANDARDS Prepared by Dr. H. C. Lewinsohn for the BOHS Asbestos Committee There is no unified position in the United States with regard to the regulation of asbestos because of the division of responsibility between different government agencies both Federal and State and the activities of groups representing manufacturers workers consumers and the environmental lobby The most vociferous lobby in the United States at the present time is concerned with environmental hazards resulting from air pollution water pollution and the use of asbestos in products contributing to these problems Organizations such as the Environmental Defense Fund and the National Resources Defense Council are vigorous and active in the field of alleged asbestos public health risks These groups of concerned citizens make their representations to the Environmental Protection Agency and to the Consumer Products Safety Commission In July 1976 the National Resources Defense Council filed a petition with CFSC requesting a ban of consumer containing spackling and joint cement products On April 28 1977 the Commission granted the petition to ban consumer patching products containing asbestos and consumer patching compounds containing asbestiform tremolite talc and a petition to ban This proposal must be artificial fireplace ashes containing asbestos published in the Federal Register within 60 days and public hearings will then follow In addition to petition rulings the Commission requested its staff to study the extent and nature of asbestos in consumer products and include recommendations for possible actions in the year review of CPSC's work due later this month May 1977 The Natural Resources Defense Council Inc. has urged CPSC to examine children's modeling clay compounds textural paints wallboard and asbestos cement sheet panel products vinyl asbestos flooring brake and linings and asbestos cement powders The Environmental Protection Agency promulgated its National Emissions Standard for Hazardous Air Pollutants M Asbestos in 1973. This standard prohibited any visible emissions of asbestos from asbestos point source categories This standard has been amended twice It covers waste disposal and it is proposed that it should prohibit the spraying of any product containing more than % asbestos The recent passage of the Toxic Substances Control Act whose purpose is to ; regulate the introduction and use of new and existing chemical substances in commerce gives EPA authority to ban any product which would pose an unreasonable risk of injury to the public Asbestos has been placed high on their list for investigation under the Act It is thus obvious that one position adopted in the U.S. is to ban the use of asbestos where it constitutes risk to the public health in spite of no published scientific evidence to substantiate the existence of such a risk Subscribing to the theory that there is no known safe level for asbestos exposure and that no evidence exists to allow a effect level to be postulated is the scientific institution constructed within the frame- work of the Occupational Safety and Health Act namely NIOSH National Institute for Occupational Safety & Health NIEHS National Institute of Environmental Health Sciences is also interested in this field NIOSH is charged with responsibility for investigating occupational health hazards and publishing criteria documents for consideration by the Occupational Safety and Health Administration in their formulation of health standards NIOSH in December 1976 document on the health effects of occupational issued an updated criteria exposure to asbestos wherein they recommended a permissible exposure limit of 0.1 fibers Their recommendation is based on the belief that the standard should be set at the lowest level capable of detection by available analytical techniques In addition NIOSH recommended that emphasis should be placed on prohibiting the occupational use of asbestos in other than completely closed operations and on substituting other products when- ever possible The present health standard for asbestos was published in June 1974 and allowed an exposure of 5 fibers per cubic centimeter 8 hour TWA until July 1 1976 when the standard was raised to 2 fibers per cubic centi- meter of fibers longer than 5 micrometers 8 hour TWA A ceiling limit of 10 fibers per am attaching a cubic centimeter longer than 5 micrometers was copy of this with marginal comments which I have set made In October 1975 OSHA published a proposed amendment to the asbestos standard which would substantially modify virtually every provision in the standard including the proposal of a 0.5 fiber per cubic centimeter permissible exposure limit For the past year and a half CONSAD Research Corporation has been conducting an economic impact and feasibility study for OSHA on the proposal In response to the NIOSH recommendation OSHA has amended its contract with CONSAD to include an examination of the availability of substitutes for asbestos the feasibility of engineering controls to achieve 0.1 fibers and the feasibility of monitoring at the NIOSH recommended level The October 1975 OSHA proposal specifically excluded the construction industry In August 1976 OSHA retained Research Triangle Institute to conduct an economic impact and feasibility study in regard to an asbestos standard for the construction industry and they too have had their contract amended to include an examination of the availability of substitutes engineering control feasibility to achieve 0.1 fiber and monitoring feasibility at the NIOSH recommended level When these contracts are fulfilled and the results reported to OSHA public hearings will follow probably in the autumn of 1977 This review would be incomplete without First and of primary importance in the fluence of the work of Selikoff and his mentioning three other factors U.S. is the exceptional incolleagues Selikoff believes that a threshold for cancer cannot be identified and that therefore standards should be based upon an appropriate evaluation of the level of risk Such an evaluation is a social decision and suitable information needs to be gathered for such an evaluation will be demanded for safety This school or else a ban believes that on asbestos best available technology should be unreasonable There the goal should be and that loose asbestos products are compensation for mistakes of the past research on demolition repair and disposal operations involving asbestos avoidance of all environmental contamination and surveillance of exposed populations The second factor is the cautious and conservative approach of industry management to occupational diseases The recorodf American industry can by no means be regarded deiln aying tactics to provide as good and the asbestos breathing space for it industry has used to put itshouse f in order I have seen working conditions in asbestos textile mills which disappeared in the U.K. twenty years ago The present climate of litigation the U.S. and the uncertainty as to what new asbestos standard will emerge has made industry nervous and ready to fight for survival . This brings me to the third factor namely the growing awareness in the trades union movement of the deficiencies in occupational health expertise in the U.S.A. which have resulted in the poor health record of American industry in general This is resulting in trades unions at national level agitating for total elimination of workplace hazards allying themselves with the environmental lobbies To further MY MY : 1 1 confuse the issue a number of States which operate their own Occupational Safety and Health Acts have proposed measures ranging from banning asbestos to acceptance of the 2 fibers standard In New Jersey where asbestos was added to a list of 15 other known carcinogens legislature be lost at a industry and used in industry a total ban was demanded in the National trades union leaders fearing that jobs would time of rising unemployment opposed the measure as did others with the result that it was defeated Selikoff is right a social decision is needed = JM Manville 5323 5323 Internal Correspondence To Paul Kotin M.D. From Gerald R. Chase Ph.D. --, Date September 13 1977 Copies Subject George W. Wright W. R. Paul M.D. M.D. W. B. Reitze R. Carter ASBESTOS ACTIVITY IN THE U.K. I met with Mr. H. D. S. Hardie of Turner & Newell on Friday September 2 1977 in London He elaborated on his comments suggesting that it was not a good time to meet with some on the British researchers As we already knew the standard setting and compliance responsibilities in the U.K. now belong to the Health and Safety Executive Mr. Bill Simpson a former trades union man is chairman of the Health and Safety Executive and is also chairman of the appointed Health and Safety Commission The commission is a policy setting board for the S Executive and it is my understanding that the commission is the formal vehicle for reports to the Minister Thus the commission is much more than advisory The commission appointed an ad hoc advisory committee on asbestos in May 1976. The advisory committee will probably disband by 1978 At that point the asbestos activities will be handled by permanent branches of the S Executive Several subcommittees are now preparing reports for the advisory committee A medical advisory sub- committee is chaired by Dr. Ken Duncan the Chief Medical is also Officer for the Medical Advisory Service which a part of the & Executive Mr. Hardie indicated that Dr. Duncan is or will be on record that without qualification data are totally inadequate and they will be 3-4 years in coming The medical sub- committee which is to report to the main advisory committee in November is likely to report that there can be no medical answer to the hygiene standard within 4-5 years in the context that at this time there are inadequate data to support or reject a cc standard Paul Kotin M.D. September 13 1977 Page 2 Professor Donald Atcheson epidemiology - S. Hampton University a member of the medical subcommittee has undertaken a literature review during four month sabbatical in Canada He will be reporting to the medical subcommittee between now and November Two new studies under the direction of Peter Elmes have been formulated Molly Newhouse working as July 1977 work on a N a consultant has begun friction materials Ferrodo plant Individual exposure estimates will be made - they may try to simulate 1950 conditions The cohort will be made up of 1950 2000 today the post Ferrodo 1949 workforce management has 1500 in made the following statements no asbestos related disease after curring dust levels prior to 1962 were probably of the order of 15 cc in dusty areas and only during the last 8 years have they been working down to 2 cc all meso about 5 cases have work histories from one department - RR brake blocks which used blue A second N plant at Tanworth has a pure chrysotile exposure history A building materials The employment records are reasonable back to 1950 A research team has not yet been selected for the study Dr. Duncan also wants to launch a study on a cohort of compressed asbestos fiber jointings and gaskets workers who have apparently had long and low exposure The BOHS subcommittee which was chaired by Dr. Gilson disbanded when Dr. Gilson resigned Berry and Peto apparently had some very lively disagreements prior to that time Peto is not a member of the new BOHS subcommittee chaired by Dr. Roach Both BOHS sub- committees have continued to look at morbidity i.e. crepitations or certified asbestosis cases Berry's analysis of the updated and enlarged cohort precipitated a meeting attended by N and TBA medical personnel and Elmex and Berry Present plans call for two papers to be published together 1 Berry's paper and 2 a dust levels paper by TBA they should be completed by the end of 1977 Paul Kotin M.D. September 13 1977 Page 3 I also spent several hours with Julian Peto He is the lead study of author on the most recent Doll mortality TBA cohorts a member of the disbanded BOHS subcommittee and probably one of the main reasons it disbanded the author of the paper that hit the London Times and the New Scientist and the one who testified to July 1977. the advisory committee on Everything of Peto's that asbestos in I have read has been above criticism from an analytical point of view He seems to be a rigorous competent investigator There have been times when he has probably not considered his audience properly or has been naive about the potential impact of his work but even then his qualifications his conclusions have been adequate but ignored by others With the possible exception of taking smoking patterns into account the main problem in Peto's work is the exposure estimation In particular area vs. personal monitoring and historical conversion and characterization Also the more basic problem of the precision and variability of the monitoring process itself must be considered e.g. the factory inspectorate is consistently counting in the range of 1/2 the industry exposure estimates right now k Peto plans to continue investigation the TBA workers he has the names and lengths of employment for all past and present workers We should activity closely follow the renewed British research plf