Document ev9kzRKD9Nwpax4weOeZBVnQE

PLAEVTtFPs EXHffirr x ihTeRnfi nun RSSOCIRTIOn OF mncHiniSTS rod peROSPRce uuorwers MACHINISTS BUILDING, 1300 CONNECTICUT AVENUE, WASHINGTON, D. C. 20038 Area Code 202--857-5200 GL15 - Asbestos May 31, 1983 935135:-. Mr. Raymond J. Donovan Secretary of Labor U. S. Department of Labor Washington, DC 20210 tSEFJCIAL CORRESPONDENCE J*fjASH RETURN TO ROOU S-2519 Dear Secretary Donovan: On behalf of our 9Q(f,000 members, the International Associ ation of Machinists and Aerospace Workers requests an Emergency Temporary Standard to reduce the permissible exposure level for asbestos to 100,000 fibers per cubic meter air. This unusual response of an Emergency Temporary Standard is necessary to meet the exceptional circumstances presented by continued worker exposure to asbestos. Assistant Secretary Thorne Auchter has been sitting on a Risk Assessment for Asbestos and the recommendations of a joint OSHA/NIOSH committee since he took office. The time for action is long overdue. jI it ' It is our understanding that Assistant Secretary Auchter is planning to propose a reduction in the permissible exposure limit to 500,000 fibers per cubic meter, as an eight hour time-weighted average. 'We know that Doctor Irving Selikoff has told him that this level of asbestos exposure is dangerously high--indefensibly high. The only exposure level that can be honestly supported is the lowest detectable level. -- - We request the 1 00,000 fiber level on an emergency basis not because it is "safe"... no asbestos exposure is safe... but because it represents the lowest reliably detectable level using current measurement techniques. In the rulemaking hearings which will follow the issuance of the Emergency Temporary Standard pur suant to Section 6(c) of the Act, OSHA should give very careful consideration to requiring measurement technology which permits reliable detection of asbestos concentrations below 100,000 fibers per cubic meter. From.our experience, we believe that for the majority of work settings an exposure limit of 100,000 fibers per cubic meter can be me 6 -^u Sing; a p.oiabinat ion of engineering and work practice control measures. lY -. 1 . . 34130 UCC 015246 Because it is veil understood that the permissible exposure limit alone will not fully protect workers from the risk of asbes tos cancer, ve request that in your emergency rulemaking you make the work practice provisions of 1910.1001(c)(2) mandatory for all operations exposing workers to asbestos, regardless of level. The specific minor wording changes we request to accomplish this are shown in the Attachment to this letter. The IAM is sponsoring a series of medical screening pro grams for asbestos-exposed workers and their spouses. The results have been devastating. 50X of our members who partici pated in the screening were found to have abnormal chest x-rays. We have also seen evidence of asbestos disease among spouses participating in this program. A national review of deaths among IAM railroad members conducted by Dr. Thomas Mancuso, IAM medical consultant, identified 42 cases of mesothelioma (see Mancuso Study attachment). These findings and the host of similar find ings by the scientists at Mt. Sinai, document beyond questions the horrible risk of asbestos cancer faced by workers and their families. Unfortunately, these serious qualitative health risks were unappreciated at the time of the 1972 revision of the asbes tos standard. However, the scientific evidence is now clear. There is a documented risk to workers and their families, demon strating a significant risk of grave danger for all exposed workers. It is therefore of the utmost importance that OSHA take steps to require full protective clothing, showers and separate change areas to protect all a s be s t o s - ex po s ed workers and their families as soon as possible, regardless of exposure level. We request that these measures be included in the Emergency Tempor ary Standard, by means of minor wording changes in 1910.1001 (d)(3). , The specific minor wording changes necessary to accom plish this are shown in the Attachment. As you are no doubt aware, the danger of cancer from work place exposure has been well documented in the scientific litera ture in recent years. These references have been enumerated by the Department of Labor at 40 F.R. 47653 (October 9, 1975), by NOISH in Revised Recommended Asbestos Standard, DHEW (NIOSH) Publication No. 77-169 (December, 1976 , ) and by the NIOSH-OSHA Asbestos Work Group in Workplace Exposure to Asbestos, DHHS (NIOSH) Publication No. 81-103 (April, 1980). The scientific evidence requires that immediate regulatory action be taken. The Reagan Administration has consistently attacked the basic fiber and web of the Occupational Safety and >! , ' \ i.: UCC 015247 413* Health Act by developing no new standards, weakening existing standards, and destroying enforcement. This neglect of Congres sional intent of the law dealing with worker health and safety must stop. The I AH demands that the Occupational Safety and Health Administration move in this direction by issuing an Emer gency Temporary Standard for asbestos. W/sm cc: Dr. Thomas F. Mancuso Dr. Irving Selikoff AFL-CIO IUD Thorne Auchter UCC 015248 Attachment (2) Work practices--(1) Wet methods. Insofar as practicable, asbestos shall be handled, mixed, applied, removed, cut, scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers. (ii) Particular products and operations. No asbestos cement, mortar, coating, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers. {iii) Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, .the removal, or demolition of pipes, structures, or equipment covered or insulated with asbestos, and in the removal or demolition of asbestos insulation or coverings shall be provided with respiratory equipment in accordance with paragraph (d)(2)(iii) of this section and with special clothing in accordance with paragraph (d)(3) of this section. (3) Special clothing. The employer shall provide, and require the use of, special clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any employee exposed to airborne concentrations of asbestos fibers. (4) Change rooms: (i) At any place of employment exposed to airborne concentrations of asbestos fibers the employer shall provide change rooms for employees. (ii) Clothes lockers: The employer shall provide two separate lockers or containers for each employee, separated or isolated as to prevent contamination of the employee's street clothes from his work clothes. UCC 015249 04133