Document pm16n3QNzLRRpqJNvYRb7RKo7

FILE NAME: Union Carbide (UC) DATE: 1977 Dec 14 DOC#: UC052 DOCUMENT DESCRIPTION: Letter to Consumer Products Safety Commission from Union Carbide Debating the Risk to Consumers from Asbestos in Joint Compound UNION CARBIDE CORPORATION METALS DIVISION P.O. BO X 579 4G25 R O Y A L AVE.. N IA G A R A F A L L S , N EW Y O R K 14302 December 14, 1977 R. David P ittle . . Consumer Products Safety Commission T ill - 18th S tre e t, NW Washington, DC 20207 Dear Commissioner P ittle : Although we are aware that the Commission has moved to publish a ban on the c^um fr use"? j S S U p l.g compounds conta in in ^ v ree-fo r, o s b ^ t o ^ w i s h risk"' i s l i o t ^ported*TM 1he"?v" u M e evidence and we question whether "due process" was properly applied in this case. During the C e s s i o n ' s consideration of the ban the " S S * }? " * ,. has provided extensive technical data on the exposure to Tree iora during the use of these m aterials. These data have included. 'as?:: is" " the proceedings th a t bear d ire c tly on the ban in question. u s " - The Union Carbide work was checked by two 1;dePn^ n` ' aS S t cTM iia n cethe''e is certainly no reason to doubt the levels J ^ J ^ ^ S S ' l ^ i y s i s inspections. In s p ite of th is , your s *a . , studv of only 30-60 minutes of risk based on exposures found in one . ^ e r c i a l y J Qns< Th1s u t t e r duration th at was conducted a t vaguel y. a l l o f the other results study showed exposures th a t were much higher than a l l of the otner resu including the OSHA d a ta . The s ta f f also based i t s estim ate on aJJh?newe1haven0f ob5eci?onSto6th l"Sas a exposures over the period of a year. While we , r ^s jcs are also maximum case, provided the appropriate exposur quoted for fiv e years of exposure a t the This number of exposures ^ ^ statutory is far beyond that which can be expa^ ahl k . we f^ ei it is extremely requirement for a showing of "unreasonable risk, we Teei it . important to draw these points to your a tte n tio n . In the in s ta lla tio n of drywall, three ^ ^ ce^ 1^edryPl^ t b r L n L d aa fte r the are made about a day a p a rt. The c?TMpu^ ' g i t i ^ e d exposures can occur second and th ird ap p licatio n . On th is b a sis, two exteiiaeo ^ room_ The during the complete fin ish in g , or ex^ n^ f . t h e ir9risk analysis thus corre- four exposures over a year used by the s ta ff in th e ir nsw , ' 000057 - 2- spends to finish in g two rooms. Although th is a n s experienced by the en , re populat o of^the ^ W? V tY s PP" g n ized as reasonable upper lim it fo r such. The fu rth er extension of P J L fiv e vears cited would correspond .bout ten (10) rooms. Exposure"? S Y e x t'e n t is so rare th a t is is not relevant and should not be used in the estimation of risk . Let us assume th a t the four exposures in a year are taken as c o r r e c t e d th a t e s tim a te ^ f^ l^ d e a th s^ p e ^ m illio n 'o v e r0a 40-year period presented by the s t a f f which is the procedure used by consumers, averaged 5.3 f ib e r s /c c ,b u t muen higher levels were present fo r ^ ^ i 2 ^ n? ^ i 12 , " S ^ r S K 2 d , !o S i? r 0J S el f u l i a| i s h f hours which is fa r longer than occurs in consumer use. is based. The OSHA compliance inspection data presented to of 0.1 to 4 fib e rs/c c during sanding and 0.6-2.7 L ifh o u r of treaso n ab le M - ^ * of ^ ` 5 5 . value of 0 .5 .fib e rs/c c in the room during the ^ " TMderT^ B ajan fio d el predicts t r i s t o f o to o it^ e x c e s td e a th to v e r 'a 40-yearCperiod per m illion persons exposed, i f the consumer data for the in s ta lla tio n of J ^ ^ e r s / c c 1??6 r ?he corresponding S s k e?So?t 'ti0eUrf in 1ishrng1of^ t a o 'i E T o v e r a year is something U ss than 0.0000001 excess deaths per m illion over a 40-year period. w as s a -sk sr r 3 i r g actual consumer exposure data to the present U. . P P , ,, s r ,,..nortiuoii is based on the -maximum not the average e*Ps^ e TM .u the assumption th a t the e n tire population is exposed a t th is max'unum i during y substantial in s ta lla tio n of drywall In two rooms. To the extent th a t these conditions are not met, the risk would be le s s . The Consumer Product Safety Act requires a fin d in g * " as a basis for the banning action by t h e i T d fo? r e f l r l n S of U.S. deaths from various causes is provided fo r reference. ^Y ng" 000058 Type of Accident or Cause U.S. Deaths* Bites and Stings 53 (1974) Lightning 112 (1974) Suffocation by Food Ingestion 2181 (1974) Poisoning in the Home 4300 (1975) Fires in the Home 5100 (1975) Falls in the Home 8400 (1975) *From 1975 ed itio n of "Accident Facts" published by the National Safety Council. As discussed above, the highest excess of risk estimate from the OSHA exposure data was 0 .4 asb esto s-related deaths over a 40-year period. This is almost 300 times less than the chances of being struck by lightning in a sin g le year and approximately 5,000-20,000 times less than the annuaJL risk from such common consumer hazards as food ingestion, poisoning, fire s and f a l l s . We submit th a t the risk from consumer exposure to asbestos during jo in t taping is not an "unreasonable risk " within the meaning of the s ta tu te . The evidence availabTe to the-Commissi on contradicts rath er than suppors the finding th a t such a risk e x is ts . Very tru ly yours, HBR/rmm J? F. Collins Vice-President 000059