Document oe7DDqqJ3YBXyzOGvpXgoXpBX

FILE NAME: Ford (FD) DATE: 1977 Feb 2 DOC#: FD071 DOCUMENT DESCRIPTION: Memo - OSHA Asbestos Standard / ** '* ' t : i- : i \ i Inter Office D. 0. Oborly cc P. N. Daknlis J . T. Cunningham W. J . Dlgneit P. D, Fudow W. A. Gainco J . W. Gutorman P. E. P r i l l E. B. Shultz W. L. Webor Personnel and Organization Statt February 2, 1977 Subject: OSHA Asbestos Standard ftie OSRA standard for oxpor.uro to asbestos dust became effective on July 7* 1972. An interim l/'VcJ of du:;t '.xjxDourc was established for an 8-hour time weighted average (TWA) not to exceed five fib e rs, longer than five micrometers; per cubic centim eter of a i r with a ceilin g or maximum exposure level of ten fib e rs , longer than five micrometers, per cubic centim eter of a i r to which "no employe sh a ll be exposed a t any tim e. .". < The standard a lso established an effectiv e date of July 1, 1976, a t which time th e TWA expooure le v e l was reduced to two fib e rs, longer than five micrometers) per cubic mt aweme*ar , As a re s u lt o f a s u it file d by the In d u stria l Union Department, AFL-CIO In ' ' v I 97U, the court directed the Secretary of Labor to re consider the July 1976 e ffe c tiv e date fo r the lower tw o-fiber lim it and the adequacy of the establish 3-year reten tio n period fo r exposure monitoring records. OSHA, through the . Federal R egister, asked fo r public comment on these issues as well as any new . inform ation having any bearing on the standard. : During the period between the issuance of the standard in 1972 and the e stab * ' llshment o f the lower exposure lim it in 1976, considerable work was done by 1 numerous s c ie n tific investigators to determine more precisoly the co rrelatio n '; between disease e n titie s resu ltin g from asbestos dust exposure and the le v e ls ^ of exposure. New developments were presented to OSHA urging the establishment, of a lower exposure lim it. - . * Thus i t came about th a t on October 9# 1975 OSHA published in the F ed eral, , '>. Regiotor a proposed rulemaking f o r exposure to asbestoB which lnoluded the lower 0.5 fib e r TWA exposure lim it. ; Manufacturers using asbestos in products supplied to us have ind icated .th at they cannot meet the 0.5 lim it without considerable expense fo r control toe&BUre PQ 8004 0618 **. . *i * .* / 5 %I t ,* 2- a t th e ir operations; and nomc have stato d they would discontinue manufacturin/ certain porta becouoe o f the added cost 1'o r co n tro ls, ` Regardless, i t in the opinion of the Employe Health Services Department th a t any m aterial, including asbestos, can be uoed oafely provided ve accept the cost penalty associated with the control measures required to protect employe h e a lth . Pragm atically, the increased coot associated with the use o f any one p a rtic u la r m ateriel oftentim es makes s a fe r su b stitu te s more a ttra c tiv e , looking a t the h isto ry of health standard development, ve estimate th at the proposed lower lim it w ill be established within the year. Further, since . aobcotos is a carcinogen to humans, we recommend th a t a search fo r su b stitu te m aterials be undertaken. In the interim , oafe handling procedures and protec tiv e control measures can be applied to processes o r m aterial handling proced ures that generate potential asbestos exposures. x a; i. < r 4 * *. *.* *i..** I. i * Robert 8, Dunham A. '' - *W> 1 ! ' i. ir. ?e.. Hi * I ii : * a-' *. .. : i i v' v 'i -* V : ' x 'V iW *. r. ^ <.i 8004 ii PQ 0619 ' U KI 'i vXtU'Uit'