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Asbestos Textile Institute,inc. Founded mi April 6, 1976 Docket Officer, Docket H-033 U.S. Department of Labor Room N-3620 3rd and Constitution Avenue, N.W. Washington, D.C. 20210 RE: COMMENTS OF THE ASBESTOS TEXTILE INSTITUTE, INC., ON THE PRO POSAL BY THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, UNITED STATES DEPARTMENT OF LABOR, TO REVISE THE STANDARD ON "OCCUPATIONAL EXPOSURE TO ASBESTOS" -- 26 CFR, PART 1910, SUBPARAGRAPH 1910.1001; FEDERAL REGISTER, VOL. 40, NO. 197, OCTOBER 9, 1975. Dear Sir: The ensuing statement constitutes -the comments of and the position taken by the Asbestos Textile Institute, Inc., to specific revisions" to the above-referenced "Occupational.-Exposure To Asbes tos" Standard, especially as it relates to the asbestos textile manufacturing segment of the Asbestos Industry in the United States. RISK MINIMIZATION Prior to issuing comments to specific sections of the proposed revision, the Asbestos Textile Institute, Inc., wishes to affirm that it totally recognizes and firmly believes that all precautions more p.o. 80X 471 Ut NORTH YORK ROaD WILLOW GROVE, PENNSYLVANIA 19090 I 'IS) OL9-:007 I ALV 0006803 COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC., TO OSHA'S PROPOSAL TO REVISE THE ASBESTOS STANDARD Page 2 4/6/76 should be exercised to preserve life, wherever and whenever possi ble. This Institute is committed to the belief that employers have a moral obligation to their employees to see that working conditions are as safe and as comfortable as proven technologies will allow. However it must be realized there will be a residual, unavoidable risk -- at work, at home and when at leisure. This face is being recognized today in the United Kingdom, as promulgated in that Nation's Asbestos Regulations of 1969.. Over the years asbestos-containing products have been known specifically as safety products -- and rightly so. The number of diseases contracted and lives lost because of exposure to asbestos ;..:-jers during product manufacture is far less than the number of lives which have been saved or the number of personal injuries which, have been prevented due to the use of asbestos-containing products Product examples, to name a few, are firefighting suits, automotive brake linings, theater curtains and industrial heat pro active lothing. SPECIFIC SECTIONS OF THE PROPOSAL SackcroJ:d Material It is felt the Background Material is too vague and general to be considered soundly supportive of the need for a limitation of 0.5 fiber per cubic centimeter of air and a ceiling concentration limit of 5 fibers per cubic centimeter. more........... ALV 0006804 n to COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC., TO OSHA'S PROPOSAL TO REVISE THE ASBESTOS STANDARD Page 4/6/7 New Evidence Seme of the New Evidence places the hazard factor on the smoking of cigarettes and not especially on exposure to asbestos. To quote directly from Section II--Toxicological Considerations of Exposure To Asbestos, Sub-Section C--The New Evidence, paragraph (2)(a), second sub-paragraph, page 47655: . . . non-smoking asbestos workers had few lung cancers while those w.- ; smoked had much more lung cancer than would have been expected r.ad they not been asbestos workers." Eased on Past Conditions We maintain that the findings cited as the reasons wh-. OSHA proposed its revisions to the Asbestos Standard are based on work conditions as they existed 35 or more years ago. Today's plants are cleaner and safer, new engineering techniques rive bee i implemented, and effective protective clothing and apparatus are now being used -- all of which have improved working conditions and certainly make for a brighter future insofar as employees ' health and safety are concerned. We feel that insufficient consi deration is being given to current, improved working conditions. We would add that work is continuing toward developing more effective methods to reduce the hazard factor -- striving for the development of technologies that will completely eliminate any hazard to the safety and health of all employees -- and still permit industry and the Nation to enjoy a healthy economic climate. more........... ALV 0006805 COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC,, TO OSHA'S PROPOSAL TO REVISE THE AS3EST0S STANDARD Page 4 4/6/76 Method of Measurement Although we are not opposed to using the membrane filter method, we would point out there is significant observer error when taking a reading of a membrane filter sample, as well as variance between obser/ers of the same sample. The reading error multiplies as fibar count levels approach zero. We suggest that OSHA permit other bonafide analytical techniques in addition to the membrane filter method. It is also suggested that OSHA recognize the limit = :ions cf the membrane filter method by specifying a plus and minu tolerance. We recommend +30%. The Icnnolocical Feasibility Approach It seems to us the proposed limitations are not based cn scier -1fica. !.'-established, dose-response relationships and, there fore che approach should be one of reaching the lowest levels that are technologically feasible. is :r contention that the 0.5 f/cc is not now technically feasible, bf'ause: (1) an accurate, reliable method of measurement has net, as /at, been found; and (2) because in some sectors of the asbestos industry, such as in certain phases of operation in asbes tos textile manufacture, the 0.5 f/cc is unattainable with today's available technology. This is not to say that, some day, solutions will not be found. Work continues and we are confident that even tually techniques will be developed and will become available that will control occupational health hazards. more........ Al_V OOOhfiOP. COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC., TO OSSA'S PROPOSAL TO REVISE THE ASBESTOS STANDARD Page 5 4/6/76 Attaining Exposure Levels The asbestos textile industry cannot, under existing available technologies, control asbestos dust levels at 0.5 fiber/cc in all of its phases of production. This is partly due to the basic pro cessing techniques which must be followed and still produce asbestos textile products as we know them today. In certain pro cesses of textile manufacture the fibers are used in a dry state. Although some of these processes cannot be totally enclosed at all times (.See Attachment I) , fiber emissions are controlled by the best engineering techniques available. LONG-TERM TIME FRAME The asbestos textile industry desires to do all it can toward reducing and eliminating any health hazard to its workers. However, an extended time period would be necessary for asbestos textile pro ducers to develop new and more effective engineering technologies toward reducing dust levels. ARE THE LOW EXPOSURE LIMITS REALLY NECESSARY? This Institute believes there is medical, scientific evidence which tends to support the position thac the "2 fibers/cc" exposure level does present a safe level. We urge that the evidence be fully studied before reaching a final determination to reduce, the exposure level to 0.5 fiber/cc. more ALV 000680? COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC. TO CSKA'S PROPOSAL TO REVISE THE AS3EST0S STANDARD Page 6 4/6/76 ECONOMIC IMPACT One might suggest that workers could be kept from getting any exposure to asbestos fibers if all work areas at asbestos textile operations were completely enclosed, if the most effective dust con '1 methods and exhaust systems were utilized, and if the usual ru2 a. of good housekeeping were followed. It might also be suggested the- -.11 U.S. asbestos textile producers convert to the "wet process" of manufacture, thereby reducing exposure levels. Our answer to both suggestions would be in the form of the ensuing question: Could we, part--ular'y in the face of low-cost foreign competition, afford to foi. .:v either of these procedures in its entirety? We say we could not in the j.iort term. A comprehensive study would have to be made tow ,rd establishing a realistic long-term time frame -- taking into account bot. technological and economic capabilities. Converting to the "wet process" would entail a complete renovatic it al. places of operation. All existing yarn-forming equipment wo have , be scrapped and all new equipment installed. But the exp-'-se wouid not end there. Since conventional asbestos textile proc-cts wo Id no longer be available, many customers and fabrica te" .. woulc 'ave to develop new techniques to accommodate the physical ar.c uhemica. differences of products made from wet-formed yarn. more ALV 0006806 COMMENTS OF ASBESTOS TEXTILE INSTITUTE, INC., TO OSKA'S PROPOSAL TO REVISE THE ASBESTOS STANDARD Page 7 4/6/76 We cannot stress enough the financial impact that would be felt in simply crying to comply with the 0.5 fiber/cc and the 5fibers/cc ceiling concentration limits. Added to this would be the expenses that would be incurred to meet several o: the other pro posed revisions. For instance, it would cost some of the larger asbestos textile manufacturers close to $.00,000 just to meet the proposed regulation that would require th~ insta.iation c.: showe. facilities. Coupled with this wo>-.id be r :.ntsna."' costs plus tie continuing wage cost per employee for the non-production time that, in order to comply with the standard, wo^ud have to be aj.lowed oh worker to take the required shower. Endeavoring to meet the proposed limitation!, could r- ell cial disaster for many of the smaller asbestos textile manufact'." - rs and fabricators. Looking at this picture, in toto, one an eas foresee, for the industry and for the communities in whic: it haj operations, a negative economic impact and a large increase in unemployment. At the national level, a product price increase sufficient r.c absorb expenses to meet the proposed regulations would not permit the asbestos textile industry in the United States to compete in the international market. The volume of asbestos textile products imported into this Country would continue to increase simDly be cause the foreign-made products would be far less expensive than mo re........... ALV 000S809 ou MXENTS OF ASBESTOS ii.Oj.Li INSTITUTE., I.^.w. , OSHA'S PROPOSAL TO REVISE THE ASBESTOS STANDARD --?= s 4/5/75 o. H the sa.T.e U.S.-made products. Asbestos textile imports in 19 72 were 5 % of report ed domestic usage. In 1975 they are estimated at 35%. We point cut the danger that th e United States may become totally da cender.t on other cou.n tries to meet its domestic asbestos textile requirements. SUBSTITUTES -OR ASBESTOS TEXTILES There are rher high-temrerature textiles available but -.o date - ne of them ha --e proven to be a totally suitiile substitute for asbestos-cental*1 ing textiles. For example: Glass fiber textiles do .ut have good _..sulati::g properties. Safety c iothipg made c: nigh : amperf : :.re s\ . - me tics offer good hear resist-: r.ce but a anno t vuth- :and . --.peratu as as high as that maut from rsbestos -contair. ..ng textiles. Si:^; asbestos text.,xes are the or..:/ cur:: . aly-av... lable materia.suit-.: for certain aoplicati ons, thus Nation cannot afford c bee m.- depe v-ant upon imports as s sole source of supplv HOW ASBESTOS FIBERS BECOME AIRBORNE Attached .-.s a complete dofini tic a of the -anner _n whica asbes tos ft. trs became airborne at each step in t: varices processes of asbesto' textile manufacture. The data indt. ite the specific proolems oi the asbestos textile manufacturer in meeting existing, torthccming a" . proposed level'- of exposure .: airborne asbe'tos r'iber. Respectfully submitted, ASBESTOS TEXTILE INSTITUTE, INC. A. Kuzmuk, CiVairman of the 3oard of Governors & President ALV OOQSplO