Document jgdkVV4LDEJXDMg6rqDKjrgbN

FILE NAME Brand Insulations BIN DATE 1972 Feb 11 DOC BIN008 DOCUMENT DESCRIPTION Brand OSHA comments on proposed standard for exposure to asbestos dust 15.01 Se reste) BRD commed AREA CODE 312 = PROZX 738-2515 2350 W. FULTON STREET CHICAGO ILL 60612 Februar1y1 1972 Office of 400 First Safety Street & Health Standards Northwest Room 305 Washington D. C. 20210 , Re Proposed Standard For : Exposure to Asbestos Dust aD : : ; : ; | woos 3 i 48 aad -- -- -- Gentlemen As thermal insulation contractors in the construction industry and being effected tremendously herewith submitting comments in in the Federal Register Volume by the above standard we are accordance with notice published 37 No. 7 Wednesday January 12 1972 Current thermal insulation specifications particularly those ap- plicable to industrial utility and Corps of Engineer process with reference to material containing asbestos work are replete evident in cements which are converted The asbestos is primarily to a workable consistency after mixing with water at the const- ruction site and in rigid preformed sections of insulation as a Thus it is obvious that the following is unavoid- binding agent able a asbestos fibres are or can be airborne immediately upon opening a bag of cement and b any handling cutting trimming and fitting of the preformed sections of insulation also precipi- tates these free particles Consequently pertaining to the above notice Paragraph o warning signs would surround cach construction site on which asbestos containing material is used Paragraph f all persons engaged in employment of a construction site so posted must be monitored Paragraph d 6 as the dust would be ubiquitous complete vaccua cleaning of a posted construction site would be a daily occurrence This and totally unfeasible monstrous task would be a nightmare Alternately enclosures to capture dust are equally unfeasible Minimally these actions STAGGERING There is no would generate costs incalculable criteria available for determining yet how tradesmen will be subject to airborne asbestos dust Like- many shall each wise this cost responsibility must be assigned i e contractor incorporate his amount as part of his bid Or shall only those contractors using asbestos entrained material be liable R. Flynn 000016 If so in what proportion is hyprocritical Ridiculous Only if this standard As opposed to further cost accruing examination of other paragraphs in the above notice we submit the following A. Substitute asbestos type cements with other types if possible Another alternative would be the employment of a mineral wool or fiberglass wrap finished with either a chloride PVC jacket or metal jacket This is being done presently but only on a relatively small percentage of construction B. In lieu of using formed insulation which has the asbestos binder substitute fiberglass on temperatures below 450 and mineral wool on temperatures above 450 C. The education of persons engaged in specificationefwforrittinwgillandbe cooperation of insulation manufacturers whereby is als expended to the end of the availability of new products necessary Finally construction work in progress which is not exempted by th standard it still another entity The same cost proportionately As these additional moneys are n are involved however impediate reflected in current contract amounts it is financially impossible to absorb this Even if it was it would be grossly inequitable the construction industry is confronted with this Inasmuch as the insul momentous challenge coupled with the fact that normally ation contractor commences work approximately six 6 to nine 9 months after a given construction project gets underway we feel the committee should be advised to consider an extension of time before enactment of said standard Hopefully at the very least it would take many months to assemble the data required in order to assess this additional cost burden to the insulation trade alon Ne cannot intepret the standard with regard to its offect on the other trades but it is pointed out here that several others are possibly involved With all due respect to the authors of the include industrial hygienists and standard some of whom no doubt medical doctors the construction industry is unique compounded with even further specialization within the industry As can be readily seen a task so comprehensive cannot be accomplished in a few weeks We appreciate this opportunity to apprise the committee of our situation but it is also our duty to submit this presentation . . \ PRIVILEOR PRIVILEOR PRIVLEOR PRIVLEOR Very truly yours - pp at . a " " " " R. Flynn 000017 15.02 BRD _ ve Lf i i , ARCTT led ACN ACN 317 PHONE 730-751 2350 W. FULTON STRECT CHICAGO ILL 60612 Office of Safety Poom 305 400 First Street Washington D.C. and Health NW 20210 Standards ; February 18 1972 Centlemen Pe Standard for Exposure to Asbestos Dust Hearing March 14 1972 As we are planning to observe the agenda to us when it becomes hearing kindly send a copy of the available Thank You Yours very truly BRAND INSULATIONS INC TJG TJa Gk Cl Thomas J. National Safety Director | 137 R. Flynn 000018