Document mq3rNEXm8k1RL5v7Yd7oB0ZMB

f tic S*^2 INTERNAL CORRESPONDENCE METALS DIVISION To (Name) Division Location Mr. W. C. Thurber UCC-Metals Division 38th Floor 270 Park Avenue New York, NY 10017 copy to Messrs. File4^ C. R. Allenbach A. L. Bayes T. W. Carmody J. F. Collins R. F. X. Fusaro J. L. Myers P. 0. BOX 579 -4625 ROYAL AVE., NIAGARA FALLS. NEW YORK 14302 o*1* October 31, 1977 originating Dept. "Calidria" Asbestos Answering letter date subject Society of Plastics Engineers Meeting, November 8, 1977 We have a commitment to present a paper at the Society of Plastics Engineers Meeting in Denver on November 8, 1977, on the general subject of Consumer Safety with Asbestos-Containing Plastics. Hopefully, the data we have been using with the various regulatory agencies will be given the stamp of authenticity by publication in one of the Society's journals. As usual, the press of other high priority items has delayed putting together the paper until the last minute. A draft is attached for your review and comments. I expect to excerpt from this for the oral presentation. In order to assist in review, the data presented are those which were used in our CPSC activities plus some spraying and grinding data that was used in California and with the current EPA spraying proposal. A substan tial portion of the text has been extracted from my CPSC testimony on the reports submitted, with little or no modification. There is a small amount of new material, including the Lawrence concept of risk-benefit, in the latter part of the paper that should be examined. If pressed for time, the key sections are Consumer Safety and Summary and Conclusions. My last day in the office before the meeting will be this Friday, November 4th. It would be very much appreciated if you could get your comments and suggestions back to me by Thursday, the 3rd, so they can be incorporated at least into the oral version. HBRrdal Attachment 71-/1. H. B. Rhodes A . / o 1} PLAINTIFFS EXHIBIT UC-1431 CONSUMER "SAFETY" IN SOME CURRENTLY-USED PLASTICS SYSTEMS CONTAINING BOUND ASBESTOS FIBERS Harrison B. Rhodes Technology Manager "Calidria" Asbestos i UNION CARBIDE CORPORATION Metals Division Niagara Falls, New York November 9, 1977 INTRODUCTION The overall theme of the meeting is Safety and Health with Plastics and this particular symposium emphasizes Consumer Safety. On the surface, these would appear to be simple, straightforward concepts, but in fact, they raise complex and controversial issues. The question of what is a "consumer" is in the courts today. The definition of "safety" is hotly contested and will undoubtedly also get into the courts. Decisions on these questions cannot be made on strictly scientific grounds but become involved in socio-political policy. The choices made can have a far-reaching impact on all of our lives. This paper will present the results of airborne asbestos fiber measurements obtained during the use of a wide variety of asbestos-containing plastics materials. The data are mostly for commercial operations but substantial consumer use^dstsrawe provided for one product. The exposure levels in them selves have little meaning if they cannot be related to the corresponding health hazard and to the current regulatory activities. On this basis the current controvery in this area will first be outlined briefly and then the data will T'o be presented in the context of0thc present situation. One product where most data are available, tape joint compounds, will be used as an example, followed by the data for the other products. Finally, a suggestion for a rational approach to the overall problem is presented. rt'S i/$- /a/ rf/f o'A'/rtro 5 r&rrs In view of the wide publicity that has been given to the health hazards of asbestos, both real and imagined, over the past ten years it may come as a surprise to many that asbestos is still in wide Xh&t aX&afcVL'. 4bout 800,000 tons per year of asbestos is,,used in this country. Of this approximately 125,000 tons is domestic production, largely from California and Vermont, and the remainder is mainly imported from Canada. A i C / uC < The quantities of the various products manufactured from this asbestos changes somewhat from year-to-year but with the exception of the recession year of 1975 has been relatively constant for the last several years. A representative breakdown from the United States Bureau of Mines and Minerals Yearbook for 1974 is shown in Table 1. If the term "plastics" is defined very broadly to include naturally occurring tars, resins and other materials that cure to a permanent set as well as the usual synthetics, a total of 364,200 or tons of asbestos^43.1 % of the annual consumption, is associated with "plastics" of one kind or another. The largest use, 153,500 tons annually, is in flooring products. This includes both vinyl asbestos tile and sheet vinyl flooring. Next comes friction products at 79,800 tons annually. These are mainly phenolic based materials for automotive and railroad brakes and clutch facings. This is jfollowed closely by roofing products at 75,000 tons per year. Included here ....... ..........? are emulsified asphaltic coatings, ^trowelable' patching compounds, and some of the tar papers. The coatings and compounds category is next at 37,900 tons. This is a conglomeration of a wide variety of products including, but certainly not limited to such things as maintenance coatings, blpck coatings, foundation countings, automotive undercoatings and sound deadeners, caulks, sealants, adhesives, tape joint compound^, etc. The last category, plastics, at 17,800 tons annually largely consists of the familiar phenolic based electrical S W"V\ fixtures, although the 700 tons of anthophylite^probably went into polypropylene for heat-sensitive applications. It is clear, therefore, for that there continues to be a very substantial involvement of asbestos with plastics and that a substantial majority, i.e., about 80% of it, is in the familiar vinyl, phenolic, alkyd and epoxy resins. The specific reasons for the inclusion of asbestos in each of these / product types varies but is generally related to several of the materials it useful properties. Asbestos is inert, "fireproof" or heat resistant, and imparts strength and dimensional stability to plastics both at ambient conditions and when subjected to high temperatures. These properties are particularly important for friction products. The strength plus resistance to mildew, rot, and weathering are important for roofing and flooring materials. When used^n small quantities in liquid systems ha$a a profound effect on rheological properties. It cfMes the materials sprayable or pumpable but sefcsy*resistant. Examples of this include flow control of paints and coatings, trowel workability of tape joint compounds, and the flow of caulks and sealants during application. The fact that asbestos is in wide use after six years of stringent regulations and tremendous adverse publicity attest to the difficulty of finding suitable replacements. CURRENT REGULATORY CONTROVERSY AND GOVERNMENTAL POLICIES In the health and regulatory arena today, both in the United States and throughout the world, the concern above all others is cancer. Testimony was IV A I C presented at the OSHA hearings art MOCA several years ago from a study^tha* showed that the word "cancer" evofkes the greatest negative or fear response of any word in the English language by a wide margin, far surpassing "death." Hardly a day passes without new or repeated stories in the various media that another material has been discovered to be a carcinogen and a new group of people, usually very large, is alleged to be at risk. Well-known examples include such familiar things as as saccharin, benzene, certain dry cleaning solvents and most recently, fluoride in water. The statement that up to 90% of cancer is caused by "environmental factors" is repeated frequently. The impression is given that the country is in the grip of a cancer epidemic and that the principle cause is industrial pollution. This is not the place to debate the issues of "epidemic" and the true meaning of "environmentally caused cancer" since they are only raised here to illustrate the climate as it relates to consumer safety activities. It would be A1 o remiss, however, not to point out in passing two recent studies that bear 4 (] directly on the subject. The first is a paper by Dr. Leonard Chiazzev ` and his colleagues at the National Cancer Institute entitled, "The Cancer Mortality Scare: Problems of estimation Using Monthly Data," wherein the statement is made that: "nearly all of the iJ&sttf# increase in the total cancer death rate from 1968 to 1974 was accounted for by the aging of the population." The second is a study by Dr. Harry B. Demopolis^ " A rational View of Cancer in New Jersey," prepared while he was the director of the Cancer Institute of New Jersey. Dr. Demopolis found that a maximum of about 4% of the total cancers could be, but are not necessarily, "industry related." While this is not intended to imply that there is not a problem withproducts produced by industry, it is clear that we are neither in the midst of an epidemic nor are industrial sources the main factor in current cancer mortality. This widespread "cancerphobia" has generated very heavy pressure on the regulatory agencies and a new approach to regulations has evolved over the past several years. This approach has two key elements, one basically scientific and one clearly socio-political. These are: 1. The one-molecule hypothesis of carcinogenesis. 2. The interpretation of "safe" to mean an absolutely zero level of risk to everybody, everywhere. The scientific concept, i.e., the one-molecule hypothesis in simplest outline holds that: 1. A single molecule of a carcinogen is capable of causing cancer in a particularly susceptible person. 2. If enough people are exposed, the susceptible person will be exposed and get cancer so that it follows that there is no absolutely and totally safe "threshold" level for exposure for any carcinogen. A i \j / u 3 fa It is useful to examine this theory in the light of where there is general agreement and where responsible opinions diverge. It is generally agreed by virtually all medical authorities that: 1. That there is a wide range of dosages for a carcinogen where a dose-response relationship exists. The larger the dose, the greater percentage of these exposed contract cancer and vice-versa. 2. In exposed populations, even at substantial exposure levels, % large portions of those exposed do not contract cancer. Some form of hereditary or acquired bodily defense mechanism is involved. 3. As the dosage goes down, the median time to the appearance of a tumor increases. The main medical disagreement occurs over what happens as the dosage is decreased to very low levels. There is one school of thought that some small number of cancers continue to occur. There are other responsible authorities who contend that a dosage level is reached where the body's defense mechanisms can effectively combat the altered cells and cancerous growths no longer occur. Supporters of this position cite the low level presence of certain metals and hormones that are essential to and are present in the human body in trace amounts that are carcinogens at higher levels. Unfortunately, there is no way to demonstrate the correctness of either view since there is a background level of cancer in both man and experimental animals. As the dosage and the corresponding number of cancers decreases, a Point is reached where the expected level disappears into the*ira*&i0jwrf background. It cannot be distinguished whether an occasional cancer from the specific agent still occurs or whether the defense mechanisms are effective so that the added cases do not occur. These views can be partially resolved on the basis of the increased time to tumor at lower dosage, i.e., a very low exposure may cause a cancer but it may take 150 years for it to occur. With an expected life span A C7o4 of 70 years this, for all practical purposes, is a safe threshold exposure at least until life expectancy approaches 150 years. Since there is at present no provable scientific answer to this risk question#, the problem becomes a socio-political . o\ decision^ what level of potential risk, if any, best serves society's overall needs. At the present time, most of the regulatory agencies are favoring an absolute zero risk to everybody, everywhere approach for all suspected carcinogens. Since there are over 2000 suspected human carcinogens, the impact of decisions made on this basis can have a tremendous effect on all of our lives. AIRBORNE ASBESTOS EXPOSURE - PLASTICS PRODUCTS The Union Carbide Corporation^TM 1963,initiated commercial mining and milling of a short fiber asbestos from a unique deposit in central California. This material is sold only as fiber and no asbestos-containing products are manu factured. In the "plastics" applications categorized previously in Figure 1 this asbestos is used in flooring products, roofing products, in a variety of coatings, in compounds and in some plastics. It is not used in fricition products. In 1972 the Corporation initiated an asbestos dust monitoring service to assist the product users in providing a safe and healthful workplace for their ih employees and .complying with the applicable governmental regulations. The data to be presented here were obtained as part of this program. Unless otherwise noted, all of the samples have been collected under field conditions as part of normal, routine, user operations. U^ao . SAMPLE COLLECTION AND COUNTING PROCEDURE Sample collection and fiber counting was carried out in accordance with the prescribed NI0SH procedure^ ^ that was in effect at the time. Since this procedure is described in detail by NI0SH, it is only necessary to touch on it briefly here. Samples were collected on 37 mm.Millipore AA filters (0.8y porosity) with a small MSA battery-driven vacuum pump. The filter cassette was attached A 10 in the collar area of the worker so that it was suspended facing downward in his breathing zone. Only data from such personal samples have been reported. For,,counting, a pie-shaped wedge was cut from the filter, mounted on a slide with the prescribed solution, and fibers we^jcounted at 400X with a Nikon microscope Model ______ with wide-angle eyepieces. A Porton reticle was used for field definition. The NIOSH procedure was originally developed to measure airborne dust concentrations where asbestos was the principle constituent in the dust. It's ability to distinguish between asbestos and other fibrous particulate of the ^ . prescribed dimensions is quite limited and well recognized (NIOSH)(NS'' 1^0 ThaSlack of specificity presents particular problems in the present or by study. Many of the samples were generated by spraying a^abrasion of plastics materials containing other mineral ingredients besides asbestos. Fiberglass, mica, various clays, fibrous talc and mineral wood were common. The NIOSH procedure permits the use of "other information" to avoid counting non-asbestos fibers but does not specify what such information must be or how \ x "Sv * f \ it is to be used. This laboratory collects bulk samples of known materials r wherever practicable and maintains a "library" of reference samples and photographs^ Cfi^ r CA-** Tvvvt'-'.'y. ^ Scanning electron microscopy is also used to a limited extent. Thi information,, (fa** 6, and counter experience's incorporated into ^ counting criteria that all fibrous Particles meeting the NIOSH criteria of length greather than 5u and aspect ratio greater than 3 wee counted as asbestos unless an experienced counter recognized them unambiguously as not being asbestos. This criteria was used for all of the Union Carbide data reported herein. LC~ ASBESTOS EXPOSURE FOR TAPE-JOINT COMPOUNDS ** fat The drywall system to be examined consists of gypsum board, usually 4* x 8', V (TA manufactured with a small beveled depression about 4" wide afewg the long edges of the sides to be finished. A paper tape to bridge the joint and a taping i-\ i \j / '-J ' rft compound to fill the depression and form the joint between the boards completes the materials used. djThe taping compound or "mud" is,,primarily-finely-ground limestone with lesser amounts of mica, clay, and asbestos. The asbestos content typically ranges from 2-5% by weight on a dry basis. The binder is vinyl acetate latex, starch, casein, or polyvinly alcohol. The compound is available as a dry powder which must be added to water at the time of use, or as a ready-mix which can be used directly. fer, ins tall ation^the aa+T boards are first attached to the studding with nails or screws. The joint is then made with three applicationsof taping compound as follows: 1. .The paper tape is buried in compound or "mud." Nail holes are filled. 2. After drying, a second coating of "mud" is smoothed over the joint and nail holes and allowed to dry. 3. The dry "mud" is sanded lightly to remove high spots and a third application is made. After drying, the joints and holes may be sanded again if a smooth wall is desired, or a textured finish can be applied directly. The potential for exposure to airborne asbestos fiber exists during the wet-out of the dry compound when it is used and during sanding and clean-up for both types. Exposure data for professional and consumer operations are available from a variety of sources. The first published information on commercial useftas that of Rohl et al' 1 , where a test was conducted at a location in New York City using professional installers. These results are summarized in Table II. A more extensive study (4) was conducted in late 1975 by Rhodes and Ingalls' ' with the cooperation of the Gypsum Drywall Contractors International. Here a variety of routine commercial sanding operations were sampled in six states. Results are shown in Table III. Additional commercial sanding, wet-out, and clean-up data from State and Federal OSHA*corrpliance~inspections have been compiled by Equitable Environment Health Inc. ' as part of an industry sponsored study of asbestos exposure in the construction industry. The compliance data and data from one short survey conducted by EEH are summarized in Tables IV and V. Consumer use data are limited to two studies recently conducted by Union Carbide Corporation. In one case, extensive spackling was carried out in one room and a 7* xll' section of dry wall was removed and replaced in a second room located two floors away. In the other, drywall was installed to cover three walls and the ceiling in a 12' x 22' basement recreation room. In both cases the three-coat installation procedures described previously and recommended by the manufacturers of the compound were .followed. A complete listing of samples and results for these two studies are provided in Tables VI and VII. In order to visualize this rather extensive compilation of data, the range of airborne fiber concentrations measured for each basic operation at each location, together with the corresponding arithmetic mean, have been shown graphically in Figures 1 and 2. Figure 1 gives the airborne asbestos fiber concentrations measured during the actual sanding operations. The commercial operations are on the left, and the consumer uses on the far right. The type of sanding, i.e, hand or pole, and the number of samples included in the average are indicated along the horizontal axis. The data of the far left are those of Rohl et al^ Their results range basically from about 1 to 20 fibers/cc >5y with averages of 10.0 and 5.3 fibers/cc for pole and hand sanding, respectively. A u3 6) The next group of results are those obtained by the Union Carbide Corporation in the survey of commercial operations in six different cities. Results range from about 0.2 to about 4 fibers/cc. The range found corresponds reasonably with the intensity of sanding, the room size and ventiafltion conditions, and the number of men operating in the same room. This reference also includes measurement of respirable dust and crystolline silica,which follow the same patterns as the asbestos,^may be of general interest. The OSHA compliance and Equitable Environmental Health data are shown next. These fiber concentrations fall in the same range as the results just discussed. The consumer-use data are shown on the far right. The first case is for the extensive spackling and the installation of three panels of drywall. The second is for the three walls and the ceiling of a large basement recreation room. This latter mud contained 2.6% asbestos by weight on a dry basis. Exposures in these tests were only 0.2 to 1.0 fibers/cc >5y, which correspond riv\^ * roughly to the lower end of the^isaege found for commercial use. Data for the two other operations in tape-joint installation which present the possibility of exposure to free-form asbestos fiber, i.e, the addition of dry powder compound to water and the cleanup after sanding, are shown in Figure 2. Here, in order to get the Rohl et al data on the graph, it was necessary to run the scale from zero to twenty as in the previous figure. Otherwise, the graph follows the same format and shows a very similar pattern. The Rohl et al data are far higher than the OSHA results and the consumer values are below or in the lower end of the range found for commercial use. When the large differences between the Rohl and Union Carbide studies first became apparent, filters from three of the Union Carbide locations were i*\ fUc f'c(r1-C counted "blind" by two other laboratories. The results shown^bcSaw demonstrate that the differences were not due to improper^counting by the authors of that A < ^ / \j o work. IHlfcKLASUK/'UUKr COilPAR 1 SUM ^ ASBESTOS FIBER COUNTS ^ ^ ______ Samp! Source_____ Location I n (Filter 1) (Filter f2) Locatltion I (Fiiter /I) (Fi1 ter !2) Location ]] II (Filter ,'l) (Fi1 ter f2) Airborne Asbestos Tiber Concentration By UCC ---- :--: * By tab A ty Lab B 0.4 0.4 0.3 0.0 0.2 0.2 1.5 1.0 1.3 1.0 1.6 0.6 0.6 0.0 0.4 0.2 0.9 0-2 Unfortunately, Rohl provides no details on the nature of the operation sampled, i.e., whether it was run as a specific test or as the sampling'of a routine commercial installation, the asbestos content of the mud, the number of men sanding in a room, the size of the room or rooms sanded, or the presence or lack of ventilation. There is no way to evaluate the influence of the specific test conditions on the results reported or to determine how they may relate to other commercial operations. The tests also appear to cover a total sanding time of no more than 15 minutes for pole sanding and about the same time for hand sanding. It can be questioned whether this is a representative sample of commercial operations but there is insufficient information to really explain the differences. The concentrations just described were obtained during the actual dust generating operations. In virtually all cases, even the commercial operators do not engage in these operations for a full shift so that the 8-hour time- . weighted average will be considerably less than the exposure while dust is being generated. Values for the sanding conditions in the 8-hour time-weighted () . k' average in the study of Rhodes and Ingalls' ' are shown in the table ofiww. The results ranged from 0.1 fibers/cc >5y to the highest value of 0.9 f/cc >5y. ^ /o FIBER COr.'CnnRAT }0:<S DUR1I.T, DRYi.ALL SAI.'DIi.'G ( ) l.ocation New York City, KY Hialeah, FL Ft. Lauderdale, FL (Hend) Detroit, I;I Pallas, TX Ft. Lauderdale, FL (Pole) Niagara Falls, 5!Y Ceiling Exposure (Tibcrs/cc >S-..-rO 0.4 1.0 1.1 1.3 1.8 3.4 3.6 Exposure 1 i ine During Sanding (Hours) 8.0 4.0 1.0 8.0 O.S 3.3 0.6 * Estinatcd D-Hour TWA Cxpi-.sun (Fibrrs/cc > 0.3 0.4 0,1 0.9 0.1 0.6 0.2 Eight-hour time-weighted average exposures have also been calculated for the two consumer installations and the highest exposure found was 0.2 fiber/cc >5y for two days while asbestos-containing dust was being generated. In general it appears, therefore, that consumer operations may be characterized with ceiling exposures of the order of 1-2 fibers/cc >5y and eight-hour time-weighted average exposures of several tenths of a fiber/cc ASBESTOS EXPOSURE F ROOFING COMPOUNDS It was shown in Table I that about 76,000 tons of asbestos are used annually in asphaltic-based roofing compounds. The asbestos is an important ingredient ___ ? in emulsified and cut-back coatings, trowel able patching and sealing compounds / and in some tar papers. It is not used in hot-melt roof coatings. Data for the spraying of emulsified and cut-back asphaltic coatings is shown in Table VII. Similar data that includes both rip-off and installation of built-up roofs with asbestos-containing materials are shown in Table IX. These data were presented by the Flintkote Company and Oohns-Manville Corporation, respectively, in response to an EPA proposal^ ^ to change the current Asbestos National Emission Stnadard for spraying of asbestos-containing materials. The results from eight field locations and test sequence ranged from 0.0 to 0.6 fibers/cc >5y and averaged 0.1 fibers/cc >5y. ^ 1 u7/ ) ASBESTOS EXPOSURE ^ COATINGS, COMPOUNDS, AND PLASTICS IX. <%*> 'h Jf1 JL&XMs-k'z These categories encompass a myriad of products consuming about 56,000 tons of asbestos annually. Typical examples include high-performance maintenance coatings, special purpose trade paints such as block coatings, caulks, sealants, adhesives, and certain laminating resins. In these products the asbestos functions primarily as a rheological agent and is usually present in small quantities such as 0.5-3% and seldom exceeds 5% by weight. Some of these products are applied by spraying and those based on thermoset resins may in some cases be subject to abrasion during finishing or in the process of subsequent replacement. 9 Data on the airborne asbestos levels during the spray3ng of nine different systems at twelve locations are provided in Tables X and XI. The highest asbestos content examined was 6% with values in the 0.5-3% range much more common. Fiber counts ranged from 0.0 to 0.6 fibers/cc >5p and averaged 0.15 fibers/cc >5y. It should be noted that the highest values occurred during the simultaneous use of fiberglass with a "chopper" gun and fiberglass s-fcefcpS Cv/s undoubtedly made a substantial contribution to the "asbestos" total reported. Data for the sanding of polyester laminating resin and of a vinyl latex paint are shown in Table XII. Results for six locations ranged from 0.0 to 0.4 fibers/cc >5y and averaged 0.16 fibers/cc >5p. Here, too, there were counting problems due to unidentifiable particles of non-asbestos material being included in the reported asbestos count. CONSUMER SAFETY JU*r The point to consider is how much risk the levels of exposure,,described pose to the consumer. It is important to recognize first of all that consumer exposure is quite different from that encountered by the worker who is manufacturing a product or the professional who installs it. These workers are exposed to whatever level of airborne fiber that is characteristic of their n /,, ti* ( particular operation for a full working day over extended,periods up to a full working lifetime. The consumer, on the other hand, may have a brief exposure while the particular product is being used and spend the rest of his lite without measurable exposure from the particular item. The best known correlation and extrapolation procedure for the risk of lung cancer from asbestos exposure is that of Enter!ine^ K In the simplest sense this approach includes the assumptions of a linear dose-response relationship with no safe threshold, a log-normal distribution of asbestos-related respiratory cancer with a standard deviation of 1.5, and a cube root relationship for median time to tumor. The log-normal distribution curve is fitted to high-level industrial exposure data or more typically estimates of past exposure to calibrate the constants and then is used to extrapolate to other exposure levels. An example for continuous exposure to four levels 1.5-15 fibers/cc >5p from Enterline is shown for illustrative purposes in Figure 3. The predicted number of cases for any given time period after exposure is found by integrating the /rv<v~ /VA< 0-+4 area under the curve^to the time ff*em exposure selected. Since the Enterline correlation deals mainly with industrial exposure levels over extended time periods, Dr. Steven Bayard^ \ of the Consumer Products Safety Commission, modified the approach for very low exposures to include an assumption that the effect of dose is cumulative. This builds a geometric increase in risk into the model which can be seriously questioned but this is not the place to debate the issue. Thi^ modification will be used to calculate cumulative risk for periods of 40 and 100 years from onset of exposure for the consumer exposure levels reported here. In the first case, following Bayard's directions in page 3, Part C, of the reference cited, for the highest time-weighted average of 0.2 fibers/cc for two days found for the consumer application^ annual exposure of 0.004 fibers/cc per day for one year, a mean latent period to tumor of 621 years, and A /7;*3 zero deaths of asbestos-induced cancer in a 40-year period after exposure are obtained. If the period examined is extended to 100 years, the number of deaths predicted would be 0.000003, which is ob'iously still far less than a single death. It is also instructive to point out that if an exposure of 5 fibers/cc for two full 8-hour days is assumed and it is emphasized that this is well above that found in commercial use, the yearly rate becomes 0.1 fiber/cc. This yds a median time to tumor of 212.5 years and an asbestos-induced cancer estimate of 0.02 deaths. For the roofing application, it seems very likely that the amount of roofing sprayed by consumers is probably extremely small since special equipment is required. The removal of old built-up roofing and replacement _________ ^ with new tar paper and trowel able emulsions by the consumer is undoubtedly quite common. The commercial data available indicates that exposures during installation would be substantially below those for tape-joint compounds, but quite possibly would still be detectable. The situation for the various coating and laminating resins is similar. While the consumer may not have access to many of these products, it is possible that he may occasionally sand certain of the coatings and finished products. In these cases a very low, but still not zero, exposure to fiber can occur. Regardless of the exposures found for the use of tape-joint compounds and the risks predicted therefrom, the Consumer Product Safety Commission is going ahead to ban this use on the basis of the "not proven safe" and "zero risk for everybody" philosophy. This is true even though the product has been in wide spread use for over 35 years and it has not been implicated in a single case of cancer. More importantly, the CPSC is very actively looking for other^ products that will be subject to the same kind of treatment. Extensive application of this approach by the CPSC and other agencies to the more than 2000 carcinogens now suspected will have a massive and chaotic impact on our way of life. A more rational approach such as that described by Lowrance ( ") is needed* ths/("safe" is defined as*; "A thing is safe if its risks are found to be acceptable." The risks are then balanced against the benefits to society to serve as a /V H fo Uit basis for a decision on where^the product.-teis. The balancing of risks and benefits is admittedly a difficult and controversial activity, but there is really no alternative. There is much that needs to be done to protect the worker on the job and the public at large. An emotion-driven zero risk approach will be self defeating in the long run and possibly in the short run as the saccharin controversy suggests. Awareness, concern, and constructive rational action^ is urgently needed. SUMMARY AND CONCLUSIONS Typical asbestos consumption in the United States is about 850,000 tons annually. Of this total 364,000 tons or 43% of the total is used in asphaltic or synthetic plastics-based materials. The largest uses* is vinyl flooring products at 153,000 tons followed by friction products at 79,600 tons, roofing products at 73,800 tons, and coatings, compounds, and plastics at a total of 53,900 tons. The regulatory philosophy towards carcinogens that is currently popular with most federal regulatory agencies was^^pTfcjVfe^ #3^ can be summarized as follows: 1. For a carcinogen an exposure level that is absolutely safe for everyone, everywhere has not been demonstrated and will be assumed not to exist. 2. The appropriate regulatory goal is a\absolute zero level of risk for everybody. 3. All carcinogens, therefore, should be banned or controlled to the lowest detectable level. Extensive airborne asbestos exposure data for both commercial and consumer use of one plastics-based material, tape-joint compounds, were presented. The consumer results show a short-term peak exposure of the order of 1-2 fibers/cc >5y and 8 hour-time weighted of several tenths of a fiber/cc >5p. Such exposures can be expected to occur for only several days out of a life time so that there effect on a person's overall exposure cannot be distinguished from the naturally occurring background. Data for exposures during the commercial use of roofing materials and during spraying and abrasion of a variety of coatings showed levels which were sub stantially below those for tap*-joint compounds. Consumer exposure*for rel-at^yHy few of these products fa* use is expected to be considerably rhc lower than,,commercial operations but are quite possibly still distinguishable from background. A risk assessment model for asbestos-related cancer that has been developed by the Consumer Product Safety Commision was used to calculate the it t Ic-^t c<~--. risks associated with the consumer exposure levels fouridA For a forty- year period following, exposure this risk was not distinguishable from zero whereas at 100 years it was 0.00003. For an exposure 250 times as high, which is well above most of the commercial data, the risk only increased to 0.02 deaths. In spite of this, the CPSC is moving ahead with a ban on asbestos in tape-joint compounds and is actively looking for other asbestos- containing products for the same treatment. Extensive application of this approach to the more than 2000 carcinogens now suspected will have a massive and chaotic impact on our way of life. A .. more rational approach such as that described by Lowrance is needed* Thus "safe" is defined as: "A thing is safe if its risks are found to be acceptable." a /Pi The risks are then balanced against the benefits to society to serve as a basis for a decision . where,, the product. The balancing of risks and benefits is admittedly a difficult and controversial activity but there is really no alternative. There is much that needs to be done to protect the worker on the job and the public at large. An emotion-driven zero risk approach will be self defeating in the long run and possibly in the short run as the saccharin controversy suggests. Awareness, concern, and constructive rational actionifi is urgently needed. H TTPE: HAND OR POLE 13 NO. OF SAMPLES TAKEN / s um jjOuoi 39/Sjdhu) 5NI0MVS TOlVrij N0UVS1N33W03 BjOIJ SOIS3HSV SHNODNIV o 'J Hi orii-Ain;; m>CMn[;r, 7QNE puf<if.r._yrr-ouT of pry iiattrials MO ClAfiyP_AfTCR SAnOHlC JET-OUT OF caT'fy._ici:'iAi$ suTTPur^.vii) clca::up " after samu.ii; ISiOP.'iE ASBESTOS CONCCUTSAV.C:, (F 'tc rs .'c c lr.r.sor th in 5 -ic ro irc tc rs ) *c RESPIRATORY CANCER AT FOUR INTENSITY LEVELS FOR A LINEAR DOSE RESPONSE RELATIONSHIP 0 & 20 40 60 00 100 120 140 IGO 100 YCARS TO O.'JSLT f{ Cj IVU 3> Sourc tr. ~ r\ ' 'j o GO ooOooo OOo oooO oo --1 t< GO f- UJ oOoooO Ok0k CO0k in0k in0k COm r-- o o oo o ooo ix k CO0k Ok0k CO0k *30"k CO CO0k CO0k O CQ CM CO LO CO Ok Ok o CO rsk in t-- GO CM in CM IX CO CM CO CO < CM 00 ASBESTOS DISTRIBUTION BY END USE AND TYPE. 1974 ' (S hort Tons) (1 ) A b stra cte d from U.S. Bureau o f M ines, M in e ra ls Yearbook, Volume 1, Page 181, Table oo I I I I I cl CM o < o o OO CM tx O o oo oo in 0k Ok OO CM OO CM OO o CoO IX co UJ _l l-H t-- o o o o o o o o o o o o o o o o o o o o o o o o o o o o o in CM0k in 0k in 0k CO0k rx 0k co0k rx 0k vo0k Ok0k Ok01 a0-k 1-- 0k 0k o0k >- in o CO CO CO on 00 Ok in CM *3- Cr VO o CO VO CO CO CM l> CO Ok o rx f-- to 4-> to TO 01 CL aasi u (/) r-- C 3 r-- JC 4-> S_ O CL GO to CD +J E to Q. -l-> to o C- +-> E 4-> o +-> (0 (U O o c c 3 o io r-- JC 3 o 0) E 01 ai E 0) TO O $- 3 TO O CD "O LU l-- TO 0k O S_ TO c o o CL k e c CL (0 l/l to CL Ok ns o r- TO~ C to 10 o o c Ok D> M 4-> o Ok o oi 4-> 4-> r-- c to to &- r-- *p* <o f0 r-- 4J c r-- r4J f-- u i~ 01 01 o 4- 3 O +-> in 4-> 01 01 JO -Cl o O U to i/> f-- (0 ra X OL JO to to r-- o f0 c S_ o Ok <o +J < < U_ QC Cl --i i-- L_ C-J Q. 1-- CL o A , G/u 1 OO z o--1 t-- 13 ex lz-H 1-- cl- lu LU lxl (_> 3 z in o i_> o hH l-H z ex UJ < 00 o UJ l-H z _J u_ l-H CO X <c CO l-H o h" IE1 CO >- LlJ ex CO a to c CD Lxl z: Z l-H QC Q OZ CO a: tCo e^-> O Sr- at 4-> +-> ro >- QJ L- r-- cr +J !-- e E I-- co 0) r-- O' O -rc s: o Oe i- a> o ai CO E <- E ro -a W CO in co * i sa-i E o E OCL +j in in CM rx O' cn o ce r 3 o O c S- (0 cn to je u CU o r--* CO o a. T3 E 3 O J- CT> -X o CO CO cn lf> r_ in CM r-- o Oo +J M 4-> CO r_ in CM r-- o_ cr> co CO in rm^ ooo 4-> 4-> +J in m o CM CO ro CO CO ID CM CM CO in in CM CM CM CM CO CM o o s- Eo +-> oe s_ in in r-- CM Lm** --* Cn TO TO C EE 33 T3 O O C S- Jro cn O) to -X xe ou "O CO CO C co CO Eo os- f-- -- -- cn e f-- X e: >> t? Q in o 4-> CO --. -- TO C 3 O L. cn X u CO CO OO s+-> c G) U ra -o IO k E o o 4-> in "O c 3 o &- cn u ro CO *3" to <3- CM oero> so m <D l_) E a> o CO o in o Ji_Z> CD E rc-- in CL a; f-- a> +o-> 3m ro s- 3 en c Ci-- r- CL e: +-> <4-- CO in 0) 4-> 3 E r-- s: in CO o <eo +- o a> u a > 0 M < <<A C Ao u-0&- ai u_ ojJ o c *" 0 40 < *- QC U_ ro cm oo O CM f-- o o CO o> -- o r ia ro <-- roi ro* -- o O Oo CO 10 o\ O LD CM CM CM CM p-- o o f-- o CM 4-- O O O o CO 10 ro r- <0 t I CO 10 o 1 10 o C(O CO *-- 10 1 10 O o oi o O CM i-- O o o o CM o d d O 1/1 c 01 o o 40 Ec 40 o c GO l/l 40 4- i. 0J 0) u Q0) a. < 10 r-- 0) 40 C o IA 40 k. 0J ai l. a. <c r-- r-. 40 40 cc o in o 4/1 40 k. k. OI oj a. 0> k. Ck < k. OJ 4- r-- 440 40 C O (A 40 k. OI Oi k. O- < 40 c o 0 k. 01 Q_ 40 c o IA 40 k. at 01 tO- < 40 c o (A 40 fc. 0) Oi t. Ou < 40 c o IA 40 k. 01 0) k. a- CM CM p-- ^ p-- CO 00 -- i0 ro CO CM CL E *-- <D to CO to #0 a. E ia i/> O EflH*- iI- L0 O *-- k. Oi O p* O (A 1 k. ro h- 00 w) * > ^ 4-> 40 1 *0 3 ct>*-- c >1 0) O Oi 1 e -- o 2 0 O k. *0 >1 0 >, E 0O >> IA 0 k. CO 40 0 Oi IA 4J C 0 -- ro c E 10 CL 10 ro 40 O 40 OO 3 IA 40 U 0 ak-r 0)4-* E 0 OI CM o>co > Ol O k. E 3 o e k. c *-- C1 O r- O o - o o> CI0 * 10 T3 4J c -- O *o > 40 C0 p* >> l1 Oi *0 0 4-> o U Q- * T5 *o c TJ 4-- Q. T3 ai 0 *0 Oi 40 C O rp GO OV+- 5 C o 4-> F-- c 0 <0 C A O IA -C c > 4-> Oi 40 E* d 4-> *-- 0) c 40 8 k. r* u 3 U 40 4-> D-V- IA 40 k. (A <4. *a c 40 40 (A E U IA O lO k. 3 IA Oi O k- IA . c0 <0 ' O IA k. a . 0E m C O) 0 Oi IA C --- >1 0) a; O IA >v Oi Oi O 20 O O <0 c >1 0i E >> 10 c IA a. s- <-- 4-j c a k. O' IA 0 S_ *- k. *0 > Oi E 0 k. O *0 E o p o q "a jz 40 40 o 3 CM 4-> o 40' O 3 40 40 3 +J -0 40 O U 40 0 C CL c oi E Oi -3 C a O 0) Oi 0 C 10 Oi 4-- C Oi 0i c Oi 0 0i 0 Oi c r-- Q. 40 40 *4- W 40 4-> CL t. +J 40 -- t 4-> p-- C 40 4J 40 O + c C 40 o u. 3 4-> lA r-- 10 GO *-- E 4- GO 40 GO 4-- E CO <0 CM E Q. 0 (A GO f-- M GO fr- 0 (A a. AIRBORNE ASBESTOS FIBER CONCENTRATIONS <a. O C_3 O <zc GO o a1O3: z 0 h< a: 0a. a: 0 0 UJ 0 C0 QC X 0 cc u. < f-- <: 0 oa. k. Oi "O C 40 0i Oi U o: -0 c 40 3C Oi C 4" CM 0 M *0 <LJ 4-1 Ob r-- 4-J 10 L- 40 *4-0 4--0 0i 3 0 -4O-l 10 t. Oi u -- ^ l Q. 3_> 4-> -O 40 u Q. C " OJ 3 <o Oi co E u U 0.4-- 3 40 0 GO 0) 0 IA z k. P- IA 0 k i ai 0 O N >t p-- 0*0 (1 L 1^. O C Oi 0 -*- k. 4-1 4. Z30 * 0 >1 C O p. O 4^ 40 u k. OO >> z Oi *0 C 40 a> oi C3 Q IA 0) E < Oi IA OCL k. 3 Cl X -- z: 0i "O C 40 o; Oi CJ cc IA 0) E c o> 1 *T3 k- OJ -- 01 4-- 0C4-* Oi -*- 0>t- 4J J 0.-0 rO C 40 E "O 3 C Oi f- IA c0 f- IA ^ E 2 O Oi OO N -0 *0 > ai C C 4-- 0) O *4- P-- u 03 00 o> 1 O k. Oi OJ r-- 0 C 4-> Oi 4-> * o>**~ M _J 0.-0 40 C 4Q E -O 3 C Oi - 1" IA CO ^ IA *-- E JU4J OO N *0 T3 >i a> C C 4-- Oi O -- 4-- k 03 00 O ll. A *O Oi > \J / v' J 40 O k. u. Oi *a 30 40 10 O 01 10 Lk. z Oi IA aO. k. 3 Q. X z: ai -a C ro Oi Oi 0z IA Oi E < 1 l 0c C O -i- Oi 0 3 * O CM *D --? IA V 01 IA Oi 40 O W 01 4-- 01 L u 4-- C 40 OJ f- *0 > 4-- k. C Oi 4-- O 40 P- Oi O 2 4-- e 0) -O f p-- Ol^-CM IA C 40 *2 *" *4- 4J O <A 4Jk*0 X *- m A 40 P-- 40 O 0i IA O a. k. 3 a. xp. -- z; Oi Q> C IO 0i Oi CD CC "O c 40 z Oi 4" O 14- z 4O- C -0 C4--M *O*- Oi X 4- f-- - 40 aiOc 0 p-- O X 4J E- c Oi CM OJ OC F- > >- z <A p-- 40 Lk 40 u 40 cn 40 p. z c 3 0 0. E O u OI X --: Q. >i o- ok. 01 <E tpO-CM 4-J 4-> C 4- O Oi Z D O p- O IA O 0> CO 40 k. j Oi < t. c *-- Oi - 40 0-- > Oi k 01 c 0 40 4-- *P- O P" ^ 0 P-- 4- +J P-- Oi c 3 2 4- Qi X -O O > 4-^ X m 4- p* O U 4- Oi 0 c 3 O Oi c. Oi E k. 0 u.! 0 X IA , Ol*4- oj c z: u>i CL I 01 a. >>0 --o QU <VI| Oi CE 4- f-- O Oi 4QCM 4-> 40 4-> 4-1 u C 4- Oi 0 *0 -0 0 0 p- 0 X IA CO 01 CM k^ c 40 O Of Oi CT> k w > c 40 40 Qi -p- P-. k 1 ^ O *-* 0 2 Oi 2 0 -- c Oi h- -O *k> > i IA *-- O Ck 40 01 c c X Cf 0 > z *0 O 40 +> 0 OI a: c x ai *4r- Q. IA Q. OZI 40 O Q. > Wl*o > a; 40 u 0 x aa; s ui *- *a c ro . Ol O T9 C 4- >i 0C 40 C 4- E -4- 40 4Q *O1-- *Q O 4-- Qi 40 E 0 IA c E0 L>.1 > U 0 O -p4- 0 0 i- lO 44 J p- IA (A p-- -p 1 1 #-- 4^ O O 40 C 2 2 E 0) H- h- irt > O U * 01 > c 01 0 AIRBORNE ASBESTOS FIBER CONCENTRATIONS Includes a ll p a rtic le s L/D >3 L>5p . Estimated by TEM proceeding to be about 50-70% c h ry s o tlle plus amphlbole. No s p lit on re la tiv e amounts Is available. c A O O aOil 4-4 3. u| (A 0) n U ia a do> .O 4- <A C U < 04 O U N, <U C iA COS. uo o O -O Sj 40 S- *- u oi u. *- JO a c - cci LU co O fs. 9 in o O o O o o ID r-- i in o IA to r* o 1 CO CM ood <o io S o c o c o 0C iA <t3 (A L. Qj s- u ai s. D_ < oi & at a. 0t-1 IfCl 01 -- r- r- O) to |Q Q. E IA LO *- E - i- O *0 |-- 31 h- 00 CM I ia r-* oo CO > ac> e *c5 OJ <0 L. iA 40 Q. C a. a> <E CM -- OO o t/i to Sa>- 0u1 a. < r-- CM m o C ca o lA C 40 /) >> E *-- 40 01 T" V C 4-> XO VI oo <-- r-- oo 10 c o M IO J- oi OJ sa. < <0 o o o 1u&0/1) in o ua u. c oo o> 3s- III I II at a) aO. Oq. il a. o CL O < - x 'Ii > T*30 <L> OZ < u. O 4-4 4</u) oo a. a. c tA TO 4- 4-4 J3 o> IA * 4-> 1 c 01 01 *rm iA najo c |A tO 4-4 r-- 40 4J *0 iA to | 0) Cl 4) c s. -C A c O O 4A (A o 2T 4- 40 u (A o 4- 4-4 tA 3 04 O J* -C (A Q> 40 3 1O c s. O -C z 4-4 *>o 40 4- o 4-* u 40 a. 4A 40 u c O* 4-4 D> c X *0J "O c -- c<0 3*.O > L O) 0c +J -rIA 4J A 01 *CX O G* a o LU o o A i 0/ 01 E sc > U0i-00> 0o) c0) a. a. 4-i 3O in c e-- CM Location B C E G H TABLE V AIRBORNE FIBER CONCENTRATIONS FROM OSHA COMPLIANCE INSPECTIONS 0) DURING WET-OUT OF DRY PRODUCT AND CLEANUP AFTER SPRAYING OR SANDING Product Identification Operation Sample Time (Min.) All purpose TJC Spray Texture^ Spray Texture('21' TJC TJC (Morter) ' Wet-out II It II II 10 10 20 2 - Ceiling Concentration Fibers/cc >5u 5.4 4.4 4.9 4.0 2.7 D TJC TJC H TJC Sweeping II II II SweepingII and Scraping II Sweeping 15 15 15 30 15 15 15 * 2.7 2.5 2.0 0.9 1.5 0.6 1.6 0.6 1. Supplied to Equitable Environmental Health, Inc. as part of a study of asbestos exposure in the construction industry. Specific locations not identified. 2. Spray texture compounds are generally similar in composition to dry-mix tape-joint compounds with texturing material added. Ar V / V..' ^ I! f*UA.U-V- 7 VV 'V-v-g-ic- l-- : o' 2 I ?|f t ij i=>' zZ 5. r t* v y w * *2 5 2 % 2 > 2 2--2-V"'2 2 hht 1 t1 : > H. -Z I 1 %* 5 : 2 1 Zi *5 22 - s:-: "I i-d Hi; i\ s 1 v . i! ll! Ill OK '5 * s ! 11 il I i e 22 52 t: :* 8r 8-- 8 -S S 1 !? ii 1 15 I! 5 S 5; 5 1 5! i 5! | ! a g5 a = 1 ! | S3? 1 s % I1 ~I 1 1s a g l . | | 1 31 s ss 5 5 s 1 s S si S s si 5 2 ! a l 1 3 -i, r^,7,u u 2 2S 5 5 : 2 22 V VV\ -Q. o \ V\ V \ V = $A x tv -- s --; v*; Xo --' -- 6/ p- k - V U ul k> w wb 9 C -- t E> 33 .C3 --b >1 bo u . * OwCc.!|,, *lrc/.5.-...'c.kN3r.t..0Vfc.w*..^..cii.sO#,.* ..Ec..Vrv.I.^c...V1-.1t.c3..kn.'*l.e..3.Vi--.)i.c'.?..Vn.Ik...nCS...*C^"<9Z. I ^ * m m. .c* -C w cc <. *- z -- -- C T k--C >o i* -- CL Cb y ? *B _ C. b ^c c c C 4. --o c3 --C i` !5 V*s Ts c- C5 k S. c *- 3. W w JC -- -2 e y ** . cr c c z .c 3 -- v -- Vw Ts i?* I Cc b *5 C k- <* b. V C V w XJ r: -- > ck cc- ^e c- - -- C *B T> * c- wc> * < -- ' C- -- T5 * JS 6 . *wc=. 3ko 5h 5c 5 C.' k w -- -- 3 - w 3 <_-- --cs --c> - *k k<- ^c. ----*3 w c c >- c- c kw c ce --.K e k "3 tw EV w3- WC 1 e-- "--o- 1c > o vx. s'! we ii t ECC3k w w. i-` Z. Cl e-< C c --* *w3 --C _C/ 3> -- -ob XO> "" - bk k3 . -I < X -- -- & 11-- SCe*^CCNnr> [.CNCCCO^-Ctc! 3 C -- -- C -- -- Ik F* 5. V*. --e^.!,ci,l <- k <s ef<k -e<v-c<--ii.<-n <--o <--i-i <i---<ifso,i j | e o -- c ~ -- -I I *k b! "x, -. cooooooooo kj. C g- M > 'j u/ s; ~ )2:23P Area. A fte r la n d in g .mdsweep up. Ifcirino (f lo 't c o a i te a d pfpi rlisc at t io n flo o o r f tape upsta jo irs i . n t lt confound, * i n room on m antle o f fire p la c e . AIRBORNE ASBESTOS FIBER CONCENTRATIONS SPARYING OF FIBRATED ROOF COATINGS- ( ) Data from response by the F lin tk o te Company to "Changes in the N a tio n a l Emission Standards f o r Hazardous A ir P o llu ta n ts (40 CFR, P a rt 61) proposed by the EPA (42 CFR No. 41, p . 12122, March 2, 1977) </> o M CO VO to o o OJ o o (/) o o <c o in r* A d> (A -4-> ro 10 CO O fO Csi CSI i- 4J I_ (J O V) 4-> --. O o o ja ai e w) K- o o u .a a> s- *r 1/1 U d) = c c .a O -r- *o o u. c 3 o S- o o cr CM CSI u o o oo GO (U Q. o TJ >, 07 i- s_ C oo 3 a. Cl O CL a. 33 00 CO < &. s- s. Q. r* r-- 00 < < to o CM 4-> on 0) -Q 00 < o i. +J 3 4-> 03 t. a. OJ tn *o C c r-- CD a fO -Q 4-> 3 O 07 F03 LD O CM cr | 1 CM 1 o 1o 1 o r-- I O 1^. CM o o in 10 o o 1 1 00 co .o 1 ,o 1 1 1 1 1 "O 4-> lo CL CL .3 1m 1 i(--1 <c 1 1 1 1 1 1 1 1-- 1 1 1 1 1 1 1 1 -*-* 1 . JC CL 1< 1 o <0 JO M 3 1 <-J 1 1 1 1 ** 1 ct> 1 o oo CO o o o ai -u s_ o CL CL 3 in s_ r-- c 1 1 1 o 1o 1 1 1 ID 1 .o Cvl O o r-- O 1 1 1 1m 1 .o tn r-- o 1 1 1 1 *o +-> i. o , CL 1 CL .3 1 oo | s~ r1< 1 1 1 | | 1 1 CO 1 CM 1 1 1 | 1 T3 07 +-> So CL CL 3 00 ir < c 1O 1 /> 1^ E 1 *-*-> 1 +-* 1 1o 1 1 J 1. o 1 1 1 1 .1 *n o 1 1 1 1 TJ ai 1 -*-* . s- o 1 ,3 1m | s- 1< 1 1 1 | | 1 1 co | CM 1 1 1 | 1 1 1 1 .E 1o 1 v> 13 E 1 U-l 1 *-* 1 , SZ 1 Q. <A 1< 1 1 US i 1 40 A . 07Ud % TABLE IX AIRBORNE ASBESTOS FIBER CONCENTRATIONS TEAR-OFF AND APPLICATION OF BUILTUP ROOFING^ * Date 3/14/74 4/10/74 5/21/74 7/25/74 11/20/74 12/16/75 8/16/76 8/16/76 Location Wisconsin Indiana Pennsylvania Indiana Colorado Colorado Indiana Indiana Operation New Application Tear-off Tear-off and Replace Tear-off and Replace New Application New Application Tear-off and Replace New Application Airborne Asbestos Concentration (Fibers/cc >5u) 0.2- 0.6 0.1 - 0.4 0.0 - 0.2 0.1 - 0.3 0.1 - 0.2 <0.1 0.0 0.0 ( ) Data from response by the Johns-Manvilie Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) ^/ r\ Staple Cowr^fclit . TOW Edo.* K-3 Ship costing. 10/2/74 *-10 K-45 iCdbUTy Costing dry dock 10/1/74 N-l (] Cot11ng pipe " Interiors. fc) Chemical'Resistant Pol vet ter J-21 Fiber-glass pipe 8/13/74 manufacture. 1 H-26 j-f j-n (Wivr r i> M-n Binder Approt-^ ^ latte Wt. 1 Asbestos Sortv Gun Type Ooentlon Cpoxy prin. 1.S 1.5 Airless " Operttor tprtylng outside 8 under e snip. 'ample Time (Min.) 33 Airborne Asbestos Coneentrat (f1bers/ec 7 ;y*J 0.2 K 0.2 Cpoxy*Coal-Ur, ttbrtnt* 1 1 1 Airless Air-supported wand. Operator spraying side of dry dock from suspended platform. Operator spraying side of dry dock from fixed scaffold. Operator spraying Interior of 3", 6* end 12* diameter pip*. 11 38 37 0.2 0 1-- 0.1 Chemical resistant resin. ' it 1.4 Airless 1.4 o.l 01 o. 7 fi,r. i> t Operator adjacent to automatic spray machine coating 28* mandrels. Operator wiping mandrels. In area near spraying. loll-tvt 140, l f>r#7 t>it l Wl 1/4 r iik*. *|i|lf \0**f Ihf |Ma Idll ta - 23 14 Ci Vi z3 0.1 0.4 O't t> V O.o 6. "V *--W* 4/tyS $*''/&*> H-7 H-3S Painting bulIding exterior. 10/6/74 Alkyd resin. * Airless 9un. Operator spraying building exterior wall. -- 9 t 0 0.0 j-n J-7 J-87 F-4 Painting building Interior. Painting building exterior. P, L<J>r fifi` *4 (fy/i 3/8/77 . " Vinyl'resin. 1.1 1.1 1.1 1.1 Airless gun. ' Operator spraying interior walls. * Operator spraying exterior walIs. 23 23 cut 0-0' 16 0 *OU 18 o.t'** M-S Veil and Roof 10/4/74 Vinyl latex 3.7 Air supported. Operator spraying IS Sprey, vertical wall panel. J-3 2.8 12 0.0 0.2 M-43 M-49 Poof Sprer. " 9/30/74 Acrylic latex. 0.7 0.7 (1) Based on toll! formulation af sprayed. Airless Operator spraying downward onto a large roof. A i U/ 28 14 0.0 0.0 c aj o to r- A >I iO *3 4. 4. C OS mCL IQ tJO- <0 U *Cf 4- 4. OS <mO ain T<3u CL| ns L 40- 0 c0l(m0 oQ.C*- o --o> 0> a> *40o-1> 40. o Q. Q3. 40). H in Q. ITS 1 o. tsao-. uo <o >> I AJT3 l4- C 01 0.40.0 US v C 04. T- o m "O 4- oi oi to l a/i 4. o. tn as o o (0 accr- o *- u o> 04- a. a. 4. 3 as in a 1 ol 4- O co in in co >*ro->>--e mm CmL O --to co 4- 4. o in oi <a aLsi.-o a4s. o>4- CL C O O T- Z <mo>n jI < AIRBORNE ASBESTOS FIBER COUNTS SPRAYING OF LAMINATING RESIN(1) Based on to ta l form ulation as sprayed. I X OS *0 4-> OL 4/-a in<D a E ^ J3 < <CL*r- 5 m to o c OS Tin m o os Ol L 3 4- CL 4. os OS XD -- 4-> c 40 in r" s- OS CO OS > C r-- OS o CJ CL U) o ! a* = J in *r. om | CL OS . 4. 4* |3 . Q. 4. 1 os , -- 4- 1 <o <n ! &- os OS > : c *-- 1 OJ o . CO CL in o os c in *-- Om a. as 4. 4. a3. 4os. r- 4-> <o in 4. oi as o CD CL CM r-s. as c** CM c *-- o #0 #4r--> U iO 4a. -ur* 1 *a o o. oc 01 34. iaa 3 4C0 a o CO c o eO-S*0* 4<00 o0*A-) ot KO LO CO co oo +au34u0s> 4- 4au3-s> aO(0. 33 4C0 4C0 as: o40 40 o CO CO CO o CM CO CO ^O *C--M II I II A ^/ o 1 t V 1^ TABIC IF- AIRGORHC ASPtSlPS ritlCR COUNTS- GRlt.DIHG AND SANDING Of POLTESTCB RCSIH-EASCD STSTTKS CONTAINING ASBISTOS Staple sicnation Comercial Application THITMOSCT P.CSIN {Polvesterl 29-82-3 ??-82-t4 29-S2-5 fabrication of reinforced fiberglass pipe. 13 6 26 fabrication of FP.P tanks and pipe. B 39 IB 12 29-E4-4 79-84-5 Production of artificial bricks. 20 Production of fiber glass boats. 75 9 . VINYL LATEX RESIN 33 Sanding of vinyl latex paint. 43 II 35 It 4 Date Asbestos Approx. Type ut. : 2/27/73 8/13/74 RG-144 2-3 2-3 2-3 RG-244 1.4 1.4 8/13/74 3/8/73 RG-244 * 1.5 1.5 1.5 No Asbestos 0 0 RG-244 2.0 2.0 11/2C/74 RG-744 0.5 0.5 3/8/77 II II N 1.1 1.1 1.1 1.1 Operation Sample Tine Operator pulls pipe along line. Saws off end with circular saw. Same operation as 1929-82-3. Operator renoving end of pipe with scarfing machine. Operator shaping er.d of pipe with bell A spigot nachine. Operator cutting off pipe end and light grinding on exterior surface. Operator grinding inside of 13' J.D. x 26' tank. Continuation of sane opera tion as 126. Operator grinding edges of niscellencous snail parts. Operator sandinq inside of 2G" 1.0. x 15 pipe. Continuation of sane opera tions as 1-15. Operator cutting with sabre saw. Operator triiTring with sabre saw. Operator grinding inside of boat hull. Operator grinding. 19 49 45 16 17 16 S 25 4 4 44 39 11 4 Operator hand sanding overhead panel. M Operator hand sanding wall panel. M JSa&B*-' Airborne Asbestos Liber Concentration (Tihers/cc -5) 0.1 0.1 0.04 0.3 0.2 0.4 0.3 0.3 4,3 2.C 0.1 0.2 0.0 0.0 12 0.3 11 0.06 16 O.lfi 16 0.0