Document npJ75prODV6gVD506zBxRXpX6

FILE NAME Manville JMA DATE 1973 May 16 DOC JMA117 DOCUMENT DESCRIPTION Letter from The Cape Asbestos Company Ltd. to M Wright See 14105 THE CAPE ASBESTOS COMPANY LIMITED 114 Park Street London W1Y 4AB TELEPHONE 01-499 TELEGRAMS INCORRUPT LONDON TELEX 24811 Mr. J.B. Jobe Manville P.O. Box 5108 Denver Colorado 80217 Corporation 16th May 1973 Dear Burt Burt M.g Burt Dear We had only a brief opportunity of discussing asbestos and health questions during my recent visit to Denver but I was able to form some impressions after my talks with the various divisions and I have been giving a good deal of thought to some of the questions that now arise I had been particularly concerned to learn that OSHA had decided to throw open again the whole question of acceptable limits of fibre concentration and it is about this that I am now writing to you You asked me about the present situation in this country and while I did give you a in rather more brief answer at the time detail The law here is I thought framed in I should confirm such a way as to this permit periodic review of the acceptable limits and at present it is laid down that below 2 fibres no special action need be taken Above this however the provisions of the is dust extraction must be provided law must be put into effect to control the dust level or that if that is not practicable then personal clothing must be provided The on the concentration and duration protection respirators protective way the precautions are enforced depends of exposure If the average concentration over a hour working period is in the upper half of the 2 to 12 fibre range the Inspectorate press for improvement in the methods of dust control If the level cannot be prevented from rising above 12 fibres in any minute period then respiratory protection is required in addition to the dust extraction equipment The limits set out in this interpretation refer to all forms of asbestos except blue For blue the figures are one tenth quoted and there are other special requirements relating to of those the use and disposal of this fibre The special requirements in respect of view that blue was particularly associated minimal exposure might be necessary blue with resulted from the medical mesothelioma and that only Tes| Mr. J.B. Jobe 16th May 1973 As you know better probably than anyone else blue asbestos has been a significant ingredient in the success of the M technique of producing the best pressure pipes in the world The technical and economic advantages and the ultimate quality of the product cannot readily be achieved by other means and they provide a significant argument for continuing the use of blue Naturally Cape is concerned to see the use of blue continued and it is to be expected that we should subject the evidence implicating blue to very careful examination It does now appear that the particular implication of blue is by no means as clear cut as it was at the time the Regulations in this country were drawn up and I feel that it is of major importance that the fullest consideration be given to all of the facts before any decision to eliminate blue is made either by M or on a wider basis on medical grounds alone The essential points in this connection are as follows : 1 There has been no marked increase in the incidence of mesothelioma in the region of the blue asbestos mines in South Africa At our own mines which have been in existence for eighty years with many long serving employees the disease is virtually unknown 2. Recent investigation at the Pneumoconiosis Research Unit in South Africa has cast further doubt upon the special implication of blue and has raised the possibility that other materials may be involved 3 Recent investigation in Britain has indicated that contrary to the earlier view appreciable exposure to blue is probably necessary before any risk is incurred 4 There is no medical or scientific justification whatever for the ten to one requirement applicable to crocidolite arbitrarily adopted by the Factory Inspectorate The adoption of separate limits for different kinds of asbestos is an unsatisfactory compromise and there are already signs that those who are seeking unjustifiably to reduce the use of asbestos will regard the lowest limits for any particular form or a ban on any particular form as leverage with which to attack all forms of fibre I am therefore anxious that there should be resistance to any suggestion of banning blue in the United States either directly or by the imposition of limits within which it is impossible to work and I feel it is important that the full case for blue should be fully considered and put before both the OSHA committee and indeed before anyone else who may be concerned \ 13 Mr. J.B. Jobe 16th May 1973 So far as M is concerned blue has been used in pressure pipe manufacture for many years and this fibre has been a very material factor in M's success as the producer of the finest pressure pipe You will know that during this period we have orientated our blue asbestos mining towards M's requirements We have always realised that one day we might have to accept that M would discontinue the use of blue on economic or technical grounds but I do hope that such a decision would not be made solely on medical grounds without the fullest consideration of the evidence and if there is indeed a prospect of this I should like an opportunity of putting the facts before your people before a decision is made Yours sincerely Wick Wick Dr. R. Gaze WFG