Document jJk0LeYrNGyzOyomrvNge3LR

pfT)wQiyUw*fmif of Near Vert utu it lb/i>- INSULATION HYGIENE PROGRESS REPORTS FROM THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM ImW* X MM. U, Pntm Dtnctm VoL 7 No. 3 and 4 Winter 1975 9Z99M001S New Asbestos Standard Proposed Cancer Risk Specifically Considered 1 PLAINTIFF'S EXHEUT On October 9. 1975, the Department of Labor proposed a new standard for occupational exposure to asbestos. The proposed standard would, among other things, lower the permissible asbestos exposure to 500.000 fibers per cubic meter of air (0.5 asbestos fibers per cubic centimeter) for an eight-hour, time-weighted average exposure, and likewise reduce the permissible ceiling exposure to five million asbestos fibers per cubic meter (5 t/ms) for any period not exceeding 15 minutes. The pro posal would reduce to one-tenth the current U.S. time-weighted average exposure standard of 5 f/ml. A reduc tion to 2 0ml on July 1, 1976 is already mandated in the current standard. Special Provisions for Construction The standard, as revised, would apply to all workplaces where occupa tional exposure to asbestos occurs, but would exclude the construction indus try at this time. However, the Occupa tional Safety and Health Administra tion (OSHA) plans to soon put forth special regulations for this segment of the asbestos industry. In the proposed rules published by the Secretary of Labor, it is stated that, "It is OSH A's intention to develop and propose a separate revision to the exist ing asbestos standard for the construe-, tion industry. Approximately threefourths of all asbestos products in 1972 were used in the construction industry. In addition, the uniqueness of the con struction industry itself (viz., the mul tiplicity of non-fixed workplaces, and the utilization of highly transient work forces) strongly suggests separate treatment. These structural differences were reflected in the 17-18 September 1975 deliberations of the OSHA Ad visory Committee on Construction Safety and Health. "Although OSHA believes that health hazards faced by employees in the construction industry with regard to occupational exposure to asbestos are similar to those faced by their counter parts in other covered employments, OSHA recognizes that alternative ad ministrative and engineering controls may be more appropriate and feasible for the construction industry. Therefore OSHA intends to consult with the Con struction Advisory Committee in order to further explore such alternatives. Upon publication of the proposal to re vise the existing asbestos standard for the construction industry, OSHA will consider the possibility of consolidated hearings on that proposal and the pro posal contained herein for all other cov ered employments." This recognition that the construc tion industry is unique is highly desira ble. Earlier data on the effectiveness of monitoring in the construction industry (see Insulation Hygiene Progress Re ports, Summer 1973), have shown that few dust counts are ever taken in this segment of the industry. Thus, spec ification of procedures is of much greater importance here. Individual workers must be able to judge whether or not they are working in a safe envi ronment on the basis of materials and methods rather than dust counts. As much of insulation is now asbestos-free, work practices for in stallation of new material can be de veloped that would lead to a time- weighted average exposure less than that proposed in the new standard. With care, even rip-out can be done safely, but special precautions must be taken. Wetting techniques have now been de veloped that would allow removal of asbestos to be accomplished within the proposed regulations. ' 7' ' -r. ~ * Millions of Workers Exposed vi.tv*- . -.-**> -- In the preamble to the standard, OSHA estimates that millions of work ers are occupationally exposed to asbes tos. They state. "An estimated 50.000 workers are involved in the manufac ture of asbestos-containing products. However, this figure does not include secondary manufacture of products which contain asbestos, such as electri cal or thermal insulation, or products which include previously manufactured components containing asbestos. "There are approximately 40.000 field insulation workers in the United States who are exposed to asbestos dust. The activities of these workers is estimated to cause secondary exposures to approximately three to five million other buildings construction and ship yard workers. However, since the dust exposure to the individual worker is extremely variable, and the number of asbestos workers at any one location is small, the primary and secondary as bestos dust exposures to all workers have never been satisfactorily esti mated." Cancer-producing Substance The impetus behind the new pro posal is the acknowledgement by OSHA of the cancer-producing prop erties of asbestos. The current United States standard was based to a large extent on one developed earlier in Great Britain and put into effect in 1970. That standard, in turn, was designed solely to protect against lung scarring (asbestosis). Cancer was recognized as an oc cupational hazard from exposure to as bestos but the British committee de veloping their standard stated that since a quantitative relationship between as bestos exposure and cancer risk was not known, it was not possible at that time to specify an air concentration which was known to be free of risk in this respect. It was hoped by the British, and by the United States agencies, that application of control measures that would protea against asbestosis would Continued on page 3 398491 ST0046627 Asbestos Risk Exists Insulation Hygiene Progress Reports Vol. 7 No. 3 and 4 Winter 1975 from Use of Taping Compounds from (he Insulation Industry Hygiene Researcn Pro gram Editor: W. J. Nlcfcoboo. Pt.D.. published a the Environmental Sciences Laboratory i Irving i Selikoff. M.D.. Direciorl. Mount Sinai School of Medicine of the Citv University of New York. N Y 10029 Adviaory Council of HHRP Irving i. Selikoff. M.O.. Program Director and Chairman E. Cuyler Hammond. Sc.D.. Vice President. American Cancer Society. New York. N Y Andrew Haas. General President. International Association of Heat and Frost Insulators and As bestos Wotkers. Washington. D.C. PURPOSES OF THE INSULATION INDUSTRY HYGIENE RESEARCH PROGRAM In spite of the introduction of asbestos-fite insulation materials and the existing bans on the use of asbes tos-containing spray fireproofing, a serious asbestos hazard remains in the construction industry, with members of the Painters Brotherhood of the Build ing and Construction Trades Depart ment being at greatest risk. Wallboard finishing compounds and spackle have been found to contain significant amounts of chrysotile asbestos, which is released into the air as dust either during the dry mixing of these com pounds or during sanding. Drywall taping compounds came into widespread use shortly after World War II. Until fairly recendy, most of the material used was mixed at the con struction site, raising large clouds of dust. In the past few years, many con tractors have switched to premixed compounds, thereby eliminating one major source of asbestos dust. This practice, though, depends entirely on the contractor and what he supplies; several tapers interviewed recendy by Mount Sinai personnel said they still had occasion to use the dry-mix brands. Sanding can be Dangerous The problem that remains, even when ready-mixed compounds are used, is that of the dust produced when the dried compound is sanded, prior to painting. In some areas of the country, tapers, or their apprentices, stay and do their own sanding; in others, the paint ers are left to finish the job. often sand ing while other men are working in the same room. Sanding is done either by hand or with a pole. The Environmental Sciences Lab oratory took air samples at selected job sites in New York City while tapers were at work. Personal samples taken during pole sanding ranged from 1.2 fibers per milliliter (f/ml) to 19.3 f/ml; in an adjacent room, at a distance of 25 feet from the sander. a level of 8.8 f/ml was found. Levels for hand sanding ranged from 1.3 to 16.9 f/ml in the breathing zone of the workers, and a high of 7.1 f/ml was obtained in an adjacent room, at a distance of 15 feet. During dry mixing, a breathing zone sample was found to contain 59 f/ml. though after a 15-minute lapse the level went down to 0.5 f/ml. The sweeping of floors after sanding was also found to stir up considerable quantities of settled dust. Thirty-five minutes after sweeping at the site of the sanding, a fiber concentration of 26.4 0ml was obtained. The current U.S. standard in industry is an average not to exceed 5 0ml. mandated to go to 2 f/ml in July, 1976. The Department of Labor has recently initiated procedures to have the standard lowered to 0.5 f/ml. The results of this sampling, espe cially when contrasted with the current standard in industry, emphasize the im portance of both respiratory protection and careful cleanup in order to reduce the risk of inhaling asbestos fibers. A respirator should be worn by sanders and by any other workers who must be in adjacent areas while this work is in progress. If possible, other workers should wait to allow the dust to settle and be removed before proceeding with Continued on page 4 1. To develop improved meth ods for minimizing exposure-of insulation workers to dusts and fumes encountered in their work. 2. To disseminate knowledge of these improved methods of dust control wherever they may be applied advantageously and to offer cooperation, advice and as sistance toward their universal adoption. r New Information on Health Effects Reviewed 8299'iOOiS Continued from page l also protect against the various asbestos cancers. Important new information has been forthcoming subsequent to the promul gation of the current U.S. standard. This has included data obtained by Drs. Irving J. Selikoff and E. Cuvier Ham mond on the mortality experience of all insulation workers in the United States. This large research project showed un equivocally the high risk of lung cancer and mesothelioma experienced by as bestos workers, and in addition, dem onstrated that gastro- intestinal cancer was also increased in incidence among asbestos workers. As data from this large study were reviewed, it was sug gested that the risk of developing cancer of the larynx, oropharynx, or esophagus was also increased from as bestos exposure. Research with the In ternational Association of Heat and Frost Insulators and Asbestos Workers was quoted many times by the Depart ment of Labor. Further studies of other large groups of workers occupationally exposed to asbestos in factory employ ment or mining and milling also indi cated excess carcinogenic risk. New Information The Department of Labor particu larly noted information forthcoming from the British Textile mill whose workers' health experience served as basis for the current British standard. "Of significant importance, new data have recently been made available con cerning the cancer risk of workers at the textile mill reviewed for the British standard, including those workers first employed after 1933. It was found that there was excess mortality from lung cancer among those workers who en tered scheduled areas after I January 1933. There was clear evidence of some excess of lung cancer and res piratory deaths among those first ex posed between 1933 and 1950. Equally important was the finding that there still appears to be an excess of deaths due to lung cancer after 15 or more years' ex posure even among those first exposed in 1951 and subsequently. Indeed, it is known that mesothelioma deaths have occurred among the specific group of 290 workers whose experience prior to 1966 had led to the development of the current standard, as detailed above." Additionally, they noted the increase occurrence of mesothelioma in workers only indirectly exposed to asbestos. where it appears that average exposure levels would often be considerably less than the projected 2 /ml standard. Shipbuilding Data Important "Of considerable industrial impor tance has been the recent description of asbestos disease among shipbuilding and ship repair workers, few of whom actually work with asbestos, but many of whom were, in the past, inadver tently exposed to the asbestos dust re sulting from the use of asbestos prod ucts by a relatively few of their work mates. In 1968. Harries of the Royal Navy reported cases of mesothelioma among shipyard workers at the Royal Navy dockyard in Devonport. in trades which did not directly involve workers exposure to asbestos, but in which there had been occasional opportunity for exposure merely by virtue of working in the same areas. This original finding has been widely confirmed and numer ous cases of mesothelioma have since been reported in former shipyard work ers. Studies of populations of current shipyard workers have shown much radiological evidence of asbestos ab normalities among workers in trades only indireedy exposed to asbestos in the yards." "Further, evidence has indicated that asbestos also acts as a lung car cinogen at levels much below those which will produce asbestosis. Two surveys of shipyard workers who had x-ray evidence of pleural plaques, but generally not of pulmonary fibrosis, showed a 2.5-fold excess risk of death from lung cancer and high risk of mesothelioma." Finally, a recent study by NIOSH was reviewed which showed that the mortality experience of underground metal miners exposed to asbestiform minerals produced a threefold in creased risk of bronchogenic carcinoma in workers. Fiber concentrations in the mine average 0.24 f/ml. In discussing considerations applic able to standards for carcinogens, OSHA stated that, "In the case of as bestos, we are dealing with a substance that poses a range of health risks to the working population. These include the threat of cancer, as well as asbestosis. In considering the controversial issue of carcinogenicity, OSHA is relying upon not only the new data reviewed above, but the leading scientific principles and options believed to reflect the research conclusions of international cancer ex perts. which were developed since or not known to OSHA at the time that the original standard was promulgated. "A. THE LATENCY CARCI NOGENIC EFFECTS "In humans, the latency period for chemical carcinogens may well extend between 20 to 40 or more years. Analogous periods exist for test ani mals. This means that the disease may undergo a long development before a tumor is actually detected. At that point, it has reached a stage where re moval of the worker from the work place may be of no avail and where treatment may be extremely difficult, if not futile. Prudent policy would there fore seem to indicate that every reason able measure should be taken to elimi nate human exposure to chemical com pounds as soon as their carcinogenic nature is identified. "B. VARIABILITY IN INDIVIDUAL SUSCEPTIBILITY IN RELA TION TO THE CONCEPT OF A THRESHOLD "Cancer development may be influ enced by such factors as the differing susceptibility of various body organs. In animal studies, it has been found that individual variability in a response to carcinogens is great depending upon factors such as age, sex. hormonal status, diet, and genetic factors. Thus, in the working population, certain groups, such as those already biologi cally compromised, may be more sus ceptible than other groups. "C. A `THRESHOLD' LIMIT "Because of the variability of indi vidual response to carcinogens and other factors, the concept of a no effect or threshold level may have little real significance on the basis of existing knowledge. While some level, below which exposure to a carcinogen does hot cause cancer, may conceivably exist for any one individual, other indi viduals in the working population may have cancer induced by doses so low as to be effectively zero. This is not to say that researchers will never find a threshold level for a carcinogenic sub stance. but it does mean that the threshold concept forcarcinogens is. at present, more a matter of responsible regulatory policy than a precise, scien tific determination. . "These theoretical concepts have a Continued on page 4 1 irw-- 398493 398494 Sanding of Spackle Material Should be Limited Continued from page 2 their own trades. The area should be cleaned, preferably with a vacuum, as soon as the dust has settled. If no vac uum is available, the floor should be dampened prior to sweeping, and the sweeper should wear a mask. Health Effects Seen Simply because sanding is only a small pan of this construction activity is no reason to minimize the importance of the problem. Although exposure du ration may be shon, the cumulative ef fect of repeated short-term exposures to measurable concentrations of asbestos fibers can be serious. In the course of a medical study of 69 drywall tapers be longing to Local 1974 of the Drywall Tapers and Painters of Greater New York, two-thirds of whom had had an exposure of ten years duration or longer and 61 of whom were smokers or ex smokers, X-ray abnormalities charac teristic of asbestos exposure were found in 37 out of 63 films. There is a close similarity between these findings and those among insulators. At least one brand of commercial wallboard finishing compound is cur rently available containing no asbestos. It is likely that, as the negative aspects of asbestos-containing compounds be come more widely known, other man ufacturers will develop new formula tions that are free of asbestos. Until then, only premixed materials should be used and the sanding of dry material eliminated or reduced as much as pos sible. Sanding of dried Jackie maerul with a pole sender. Dost cooceantioos hen often exceed the cental tshescw ondard. Comments Solicited on Proposal Continued from page 3 bearing on the asbestos issue, particu larly as to the question of the existence, or nonexistence, of a threshold level of carcinogenic effect. A no effect level theoretically may exist, but it has not been demonstrated. "In previous rulemaking proceed ings. OS HA has considered these is sues and determined that in the absence of evidence to establish a safe level on the basis of present knowledge, em ployee exposure must be reduced as low as feasible." In a further discussion of the major provisions of the proposed standard. OSHA explicitly recognized that, "since the promulgation of the current standard, several distinguished indi viduals and many agencies, both public and private, have made vduable con tributions to the field of toxic sub stances generally, and asbestos spe cifically. "Exposure Levels. Recently, the National Institute for Occupational Safety and Health (NIOSH) has in formed OSHA that it is currently re viewing data which may provide signif icant information with respect to the margin of safety afforded by the exist ing asbestos exposure limits. In a memorandum dated 29 September 1975 to the Deputy Assistant Secretary of Labor for OSHA, the Director of NIOSH stated: Multiple and consistent epidemio logical studies leave virtually no doubt that asbestos is carcinogenic to man. r> "OSHA also believes sufficient medical and scientific evidence has now been accumulated to warrant the designation of asbestos as a human car cinogen. Therefore, it is incumbent upon OSHA to propose the establish ment of safeguards to protect the lives of affected workers. No Safe Level for a Carcinogen "OSHA deems it appropriate to propose that the 8-hour exposure limit (TWA) be lowered to 500,000 asbestos fibers per cubic meter (0.5 asbestos fib ers per cubic centimeter), and that the ceiling exposure limit be 5,000,000 as bestos fibers per cubic meter (5 asbes tos fibers per cubic centimeter) for any period up to 15 minutes. OSHA recog nizes that there is no assurance of a safe exposure for a substance with known carcinogenic property, in this case as bestos, and thus there should be no de tectable concentrations. However, the Act requires that the Secretary establish standards to extent feasible, and there fore the Secretary must take into con sideration technological and economic factors. "OSHA believes that it may be ap propriate to postpone the effective date of the proposed exposure level because of the existence of problems of feasibil- (/> icy of a technological and economic na-__ | ture. OSHA expressly invites com-1--i rnents on this issue, including comment q on the appropriateness of a phased schedule for compliance with any new^ exposure level, based on such feasibil- ity factors. In this respect. OSHA particularly invites comments on the struc- ^ ture of the asbestos industry generally including factors distinguishing par ticular sub-industries in terms of meth ods of asbestos use and capabilities of compliance." The deadline for submission of comments on the proposed regulations is December 8. 1975. Additional provisions in the proposal put forth by OSHA would "extend the retention period for medical and monitoring records to forty years, or for the duration of employment plus twenty years, whichever is longer; provide procedures for the transfer of medical and monitoring records of certain former employers; require specific min imum data on medical and monitoring records; revise the procedures for initial and subsequent monitoring; modify the definitions of asbestos and asbestos fiber; add provisions for employee hygiene, information and training; re vise and update the requirements for respirators, and warning signs and labels; and establish a time parameter for sampling ceiling concentrations. In addition, the proposal will suggest work practices to be followed for cer tain operations and processes involving asbestos." Of particular importance is a pro posal that would add sputum cytology as a diagnostic test. This is proposed only for workers who are forty-five years old, or who have been employed in die asbestos trades for ten years or more. Here, analysis of cells coughed up from the lung may be useful in indi cating the early stages of lung cancer, at a point where more successful treat ment can be accomplished. This proce dure was recently proposed to NIOSH by President Haas for all members of the IAHFIAW and is being considered by the Institute. ...