Document oMkOodEJZmGXB5OkjXR7nmvNR

M EMORAMPUM TO; Messrs. T. Dougherty A. Miller R. W. Stobaeus B. K. Barton *J E. Skvarla N. j. Setter R. T. Larkin DISTRIBUTIO3N ^ DATE: W. T. Cohan J. A. Riddle K. V Wood 53'"/, L. F. Crow G. C, Brice September 9, 1966 CC; L. S. O'Rourke D. S. kamers SUBJECT: Asbestos* - Toxicology T. J. Hall K. West H. F. Reichard/R. G. Woolery G, Vessels t/J. A. Riddle y& ^ ... J. Derbecker P. R. Cheston Shifters 0 A, A.. . Andrade _ ,,. DECEIVED T. F. Frangos Gentlemen: U.c.c. - MNe. c, metals oiy calif. ' Attached are "tear sheets" from some of the most recent publicity in respect to the subject. The one article appeared in the September 10 issue of CHEMICAL WEEK; the other was passed along to us by Peter Cheston, and appeared in the LONDON SUNDAY TIMES of August 14. . There is no doubt this kind of publicity will persist, and it is important that its inapplicability to our products and our applications not be missed by our customers ana prospects. You have some positive positions you can and should take with your customers: 1. It is important that you continue to use Dr. Dernehl's "Asbestos Toxicology Report" as well as the statements made by the Food and Drug Administration {Department of Health, Education and Welfare). I am attaching copies of each; if your file supply of these is de pleted, you can either run off copies or get addi tional from us. 2. In the CHEMICAL WEEK article, if we look at the summary of "sources of airborne asbestos", we see that, to our knowledge, our products now are used only in modest ar.cunts in ceiling and floor tiles, and here in rela tively low concentrations. Further, these are applications , employing particularly good resin binders, making the loss of asbestos to the air from such compositions appear highly unlikely. UCC 023078 . -2- 3. You will recall (my memo March 26) that there has been medical literature reference to the association between cancer and polycyclic aromatic organic compounds found with certain sources of asbestos -- among them jute oils from sacking materials, and 3,4 benzo(a) pyrene. Union Carbide uses no jute bags. Analytical tests have established the absence of organic material with Union Carbide asbestos. Some time next week, we expect microanalyses to show specifically no detection of polycyclic aromatic compounds with Union Carbide asbestos of our different grades. Please note the primary concern in these publications deals with "airborne asbestos" - and Dr. Demehl has stated clearly that "while asbestos dust in excess of the Threshold Limit Value is potentially harmful, as are many other dusts encountered in industry, it is as readily controlled as other dusts and it can be used safely with appropriate precautions". We should take the positive position, important to our customers, that Union Carbide produces and supplies this commodity in pelletized form, a major step in assisting the user to control his own dust hazards. We feel certain this factor has been a prominent one in the decision of certain of our floor tile customers to shift toward . use of Union Carbide product. Very truly yours A.E.Pufahl:dk attach UCC 023079 Taking Giant Steps Two chemical process companies took giant steps toward diversifying into the oceanography field last week, and two paper companies with com bined sales of nearly $1 biUion/year reached a tentative agreement to merge. (1) Bendix Corp. (Detroit) ex panded its oceanic activities by ac quiring for an undisclosed amount of stock Marine Advisers (La Jolla, Calif.), producer of oceanographic in struments for petroleum and utility companies, state and federal agencies, and firms engaged in scientific pro grams. ' (2) Fluor Corp. (Los Angeles) and B. L. McFarland and Associates (Fort Worth and Midland, Tex.), a group of five companies involved in offshore and onshore drilling opera tions, have agreed to merge, subject to stockholders* approval. The Mc Farland group operates five offshore drilling rigs in the Gulf of Mexico. (3) A tentative agreement to merge has been reached by U.S. Plywood Corp. (New York) and Champion Parers, Inc. (Hamilton, O,). It is sub ject to both directors' and stockhold ers' approval. The corporate identities bctb companies will be preserved. Educing Gas Rates The Federal Power Commission has ordered El Paso Natural Gas Co. and Transwestern Pipeline Co. to reduce by S17 million/year the price of na tural gas, in the southern California market. The rate cut stems from the July 26 decision in which FPC turned down the application of Gulf Pacific Pipeline Co. (a Tenneco subsidiary) to supply gas to the Los Angeles area (CW, Attg. 6, p, 20), Gulf Pacific lest week filed for a rehearing. El Paso and Transwestern were told they would have to lower their rates to reflect the lower costs result ing from the bigger deliveries pos sible in the expanded system. At the same time, FPC said it would conduct further proceedings to decide if cus tomers should get additional benefits resulting from more liberal deprecia'ior. allowances. r PC has given the companies 45 days to show cause why the reduction should not take place. Sources if airborne asbestos Asbestos-lined ducts used in centrally air-conditioned buildings. Asbestos ducts and insulation in home central-heating plants. Motor vehicle brake linings and clutch plates. Auto undercoatings. Asbestos ceiling and floor tiles. Asbestos shingles and sidings. Construction and demolition Fitting, cutting, and removing asbestos-filled wallboards and floorings, piping and insulation. Incineration of asbestos-filled scrap. Improperly filtered effluent from asbestos processing plants. Asbestos: Awaoting Triiail' The asbestos Industry--whose end products are valued at more than $500 million/year--may be in for a shakeup. It could come in the form of federal legislation limiting the use of asbestos, because asbestos has been ac cused--though not yet "convicted"-- as a significant health hazard. Prob able contender for asbestos markets: plastics. Recent studies have convinced U.S. Public Health Service specialists and other medical authorities that about 40% of all Americans have mild, chronic cases of asbestosis, even though most of them never worked directly with asbestos. Unlike other airborne dust particles, asbestos fibers have the ability--al most as much as activated carbon-- to absorb polycyclic hydrocarbons and arsenicals. Furthermore, says USPHS, in the past 30 years the as bestos-related cancer rate has in creased sixfold. The Inferences: While the average asbestos worker is well protected, the man on the street is not. The 3x1micron asbestos fibers in his lungs can come from a variety of sources (table, above). And medical experts say there's no way to assess hydrocarbon content in those lung deposits, American Cancer Society research ers feel certain there is a synergistic relationship among airborne asbestos, smoking and lung cancer. They reason that the nondegradable, hydrocarbonsoaked fibers may well be a constant source of lung irritation. PHS officials think it may take them up to five years to establish asbestos' true role as an air pollutant. However, Congress may act before the research is. finished. Says Repre sentative Robert Watkins (R., Pa,): "We've seen enough evidence al ready. Asbestos will never get a clean bill of health. With just a little more data we'll move for controls and strict ones," Some form of asbestos control is in the offing, public health officials are certain, if only part of a larger clean-ambient-air program. However, there is the danger that Congress may enact rigorous controls on the quanti ty of asbestos that could be used. In that case both Canada and U.S. asbestos products manufacturers would be hard hit. Of the five forms of asbestos mined today, chrysotile asbestos holds the predominant mar ket position because of its insulat ing and processing qualities, Canada produces more than 80% of the chry sotile asbestos used in the U.S. In both countries, a number of serious dislocations would occur. At present, there is no known ma terial that could fill all of asbestos' strategic roles. On the other hand, should federal controls merely call for higher standards for binder? and shieldings, that would spark a rise of new products, with plastics '.nk:rg the lead. Reason, say Industry spokesmen, present polymer technology could easily turn up products to replace as bestos in most end-uses. 32 CHEMICAL WEEK Septembe- IC, ICES UCC 023080 ,\ y ; l 1 VV o "A M D a a/ ii lAH 51 vJ ',>' >l> 'v-^ i' ; = ; A :-, . 4. A. .Va,.s_/ '''.. fpj *'T; TO. /^f}/T;"* TV^T: `O !'-r Cl'Oih3 Li ii. By Br Alfred Bvvuc ] REGULATIONS which acknow- There arc throe typer, of ; ledge that occupational exposure asbesbi; used conunevcir.Ly-- to asbestos is causing the most c!iiysniiie. ciocidoiiie and .-ova's.;ito I important industrial cancer of our --whoso possible hazards are now ! time will be introduced next week being ossesw'd hi (hr laboratory by .Miss Margaret ilerhisou, Mini and ; ... dt-ui. '. .r., ; Gib ... ; SU'f ilf Stil.'iaJ GfCUJ'ilj'. eit.'iLi lUuri, Ifie ini ,i.g. ;f.:,i f ;.,..u i' i util Align-,i `.hi I he luiut.iir llr.ati. .1 t......... . i;, ,u rurp.iir | lujiivvh :,, mi-uniUelLimbi will lie IbciiiMU;! -.in \in ..re.i, v, I,,".; :-! i ri 111i! < ,| Mi " pIT: ClbCll (Hilv i ni' I v | h hi iilire |i-. . .r- e,i. j disease," mi idel asbestos vortver.s ttuoies in ( oiuis Ainr,. i. e.e ! v. in- contract it us a result of already shown -that the .......... . is j tlivir occupation after a certain inoi'e connnoe, ;u the neigh 'our1 dine wilt be eligible fur industrial liooxl ot mines prodiicin;-: vroc.hoi benefit. Mesothelioma is an uu- hte than amusite. To complete the ; usual Tumour of the pleura-- picture tin* committee are anxious : covering the iuni;--and of similar to are a similar study performed tissue lining the abdominal in Canada in relation to mines j cavity. and is invariably fatal. producing cUrysoUle. I Several steps are being taken tn* Pathologists in British hospitals | wards discovering the full ciTeets are also going hack through t'netr i of this recently - recognised records in sec if mesothelioma disease so that measures to pro a " new " disease associated with ] vent it can be devised, tlie commercial use of :u iv-oos, | A,,' register of "all [mat ami and checking if il is peculiarly ; present eases oecurrin." in IniUiin relaicd to certain districts. They bus oei-n set up by the Medical are also studying the incidence : Research Council's Pneumo- of asbestos particles in hi tigs : tuhioiis ^Research Unit, directed examined post mortem, in .cities ! by Dr. J. C. Gilson, in Cardiff. of tiie U -S, South Africa and They have added TO new cases Britain the lungs of middle-aged to their original nucleus of 120 ami older people have been found i since the Sunday Times broke'the to contain asbestos bodies in from | news of this epidemic on October 5 to dli tier rent, of cases, tint 21, JObo, One hospilal hi Lon tin- medical significance of This, if don and aimihei- in llelfa.ir are any, remains In be decided. each admitting an average of one new case a month. Advised by a comnultee of experts, due Ministry of Labour | An average of 40 years usually is drawing up a new code of J elapses between exposure to rei'ulaltons designed to give I asbestos ami the appearance of persons working with asbe-.fos j the growth. Exposure for only ill ore protect inn than iiiey have two or three months may cause had from the general factory the cancer. Living near an regukn i.-nis, A.sbeslOs is now used I asbestos works predispose.-; to to mak.; "utters, "noting, tiles, i mesothelioma, and relatives of brake-linings and numerous olher I asbestos workers can also pet it things noL envisaged when Ike | through inhaling; asbestos fibres risk of asbesiosis was first i given ot: tile clothing of their realised. ! menfolk. The of.ieiai proposals will Muon patients were not wmkinti therefore inelude several occupa with asbestos, so they will not tions to winch not enough thought he eligible for eomponxotie.u is riv^U ill, mww toe industrial Injuries Act standards of dustiness win pre of 1047. Incredibly, perhaps, sumably in- proposed for workers l.ie-f- are also otlier me; ot Pel ioma exposed in special risk, such n.i vicums who are not eligible under till). -'' in i:,e textile iud-iMry an ' the new regulation hot awse tlu-y Ti:*-.- .;.c.a-,v<i :n iaggiti'.' hut p., worked'for a short tune in ihe It is imp'd tii.d Hie tfrst olliciid industry only before the ne w Art pro.ais,;! i will lie made known by.-' ` ; : ( ,'ll'Vc, Hi..... e , j ; ii; . ., UCC 023081 j'/l' - Ik' UK3CAS CARD1D2 CORPORATION 270 PARK AVENUE, NEW YORK, N.Y. 10017 ASBESTOS TOXICOLOGY REPORT It has been known for many years that seme persons working in asbestos production were prone to develop a disabling lung disease. In time, this condition became known as asbestosis and was related to exposure to high concentrations of asbestos dust, With further experience, it was found that men could work with asbestos without development of lung disease if dust concentrations were kept below a certain level. It is now gen erally accepted that a man can work a 40-hour week for a lifetime without developing asbestosis if the asbestos dust particle count is kept at or below 5 million particles per cubic foot of air. This dust concentration of 5 million particles per cubic foot of air is the Threshold Limit Value for asbestos, and no cases of asbestosis are known to have occurred when exposures have been maintained at or below this level, despite large-scale utilization (now approaching one million tons per year in the U.S.A.). This concentration of dust is generally not visible in the average work area unless a beam of light causing a Tyndall effect is present. Usually the dust concentration must be from 8-10 million particles per cubic foot before its presence is visible in average lighting conditions. Several years ago, it was reported that there was an increase in the incidence of cancerous tumors, especially of the lung, associated with asbestosis. Recently there have been reports of some cancers occurring in individuals exposed to asbestos dust, but who have not developed clinical asbestosis. It is believed by most authorities that these cases have been associated with exposures significantly exceeding the Threshold Limit Value. A major manufacturer of asbestos products who also mines asbestos has not been able to show an increase In cancerous growths in men working where dust concentrations were maintained at the Threshold Limit Value. Control of asbestos dust exposure is therefore necessary. The control methods are the standard ones applicable to a variety of dusty operations. They include closed flow systems, wet processes where possible, and adequate exhaust ventilation where openings in the system are necessary. Felletizing is sometimes used to improve the handling character istics of otherwise dusty materials. Where satisfactory containment to stay within the Threshold Limit Value is impractical or impossible, efficient and reliable respirators are available for the protection of the employee. A program of environmental monitoring is highly desirable to determine that Threshold Limit Values are not being exceeded. In paper manufacturing, it would be desirable to know the dust concentrations where the asbestos is dumped from bags into the pulp slurry. Concentrations should also be determined where dusting occurs in finishing products. While initial dust determinations should be made at frequent intervals, once the level has been established as satisfactory, the frequency may be extended to occasional tests to assure continuation of a satisfactory condition. UCC 023082 -2Pre-employraent and periodic physical examinations of workers are desirable. These should include chest X-rays to insure that the worker has no chest condition prior to work with asbestos and to determine that no lung changes are resulting from work with asbestos. It is believed that the addition of asbestos at the proposed levels during the manufacture of paper products would be harmless to the consumer. Total dusting would have to be well in excess of any levels acceptable to the consumer for the asbestos concentration to approach the Threshold Limit Value. In conclusion, while asbestos dust in excess of the Threshold Limit Value is potentially harmful, as are many other dusts encountered . in industry, it is as readily controlled as other such dusts and it can be used safely with appropriate precautions. Carl U. Dernehl, M. D. Director of Toxicology K. S. Lane, M. D. Assistant Director of Toxicology UCC 023083 Our Law Department advises us that the attached exchange of letters with the Food and Drug Administration means that FDA is in agreement with us that the use of asbestos fiber as a component of paper and paperboard used in contact with food is safe and is in compliance with the Food and Drug Act and that no specific regulation under the Food Additives Amendment is necessary. Our letter to FDA is dated October 31, 1963. Their reply is dated December 6, 1963. The correspondence is between Mr. Scriba of our Law Department and Mr. Cassidy of F.D.A. UCC 023084 DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE FOOD AND DRUG ADMINISTRATION WASHINGTON SS;D.C. 20204 December 6, 1963 Mr. George T. Scribe Union Carbide Corporation 270 Pari: Avenue New York, New York 1001.7 Dear Hr. Scriba: Reference is made to your letter of October 31, 1963, relative to the status of an asbestos fiber as a component of paper and paperboard. lie concur that when used consistent with the principles of .good manufacturing practice asbestos as an inert filler in paper and paperboard does not have food additive status. Therefore, there is no necessity for a regulation to prescribe the use of such asbestos fiber as an inert filler in such paper and paperboard. Sincerely yours. Frederick A. Cassidy Food and Drug Officer UCC 023085 >. 1V UNION- CARBIDE CORPORATION 270 PARK AVENUE NEW YORK, N. V. 10017 Law DEPAATStEiTT October 31, 19&3 Food and Drug Administration Washington 25, D.O. Re: Asbestos Fiber Gentlemen: . . (1) This is to inquire whether you are in agreement with- us that.the use of asbestos fiber as an integral component of paper and paperboard does not result, and may not reasonably be expected to result, directly or indirectly, in its becoming a component or otherwise affecting the characteristics of the food when the paper or paperboard is employed in contact with food. . ' (2) If not, whether you are in agreement with us that this use of asbestos fiber is generally recognized as safe among ex perts qualified by scientific training and experience to evaluate its safety. ' . (3) If not, we ask you to file this letter as a petition for a regulation under Section 49 of the Federal Food, Drug and Cosmetic Act stating that this use of asbestos fiber is safe. We propose to sell asbestos fiber for this use. Responsible paper manufacturers tell us that it improves the quality of paper and paperboard for certain food contact use. We base this petition on the generally known physical characteristics of asbestos fiber. While we write in terms of "asbestos fiber" without limitation in view of your presumed interest in a broad regulation, our company's direct present interest lies in chrysotile asbestos (a magnesium silicate). We attach a table entitled "Solubility and Dissociation Data for. Chrysotile in Water'1 from The Journal of Physical Chemistry, v Vol. LX (195^) page 1220, and our summary of "Properties of Chryso tile Asbestos.Fiber". We respectfully propose the following regula- tion: 1121.__ Asbestos Fiber. Asbestos fiber may be safely used as a component of paper and paperboard intended for use in producing, . manufacturing, packing, processing, preparing, treating, packaging, transporting, or holding food. ' Very truly yours, UNION CARBIDE CORPORATION . . ' GTS:R enc. . -. ' By' George T. Scriba . :. ' .. . 1 - UCC 023086