Document qXG4vQvMYrp0wJdb7nkk0qbj

,*-/- u >r ' ^rj'7'5 P\\r- i K^r- EQUITABLE ^3/ oo'f/hJ>nso ENVIRONMENTAL HEALTH INC ^SUCCESSOR.TO'^ENVIBOnKiENTAL ANALYSTS. INCORPORATED AND TABERSHAW / COOPER ASSOCIATES A Subsidiary of The Equitable Life Assurance Society of the United States VV. CLARK COOPER, M.D. Vice President PLAINTIFFS EXHIBIT EEH/S-76L-345 August 10, 1976 John J. Welsh, M.D. Corporate Medical Director Union Carbide Corporation 270 Park Avenue New York, New York 10017 Dear Dr. Welsh: I am enclosing a brief report of my visit to King City on June 30th, with a few recommendations. As you can see, there is nothing to in dicate asbestosis in the four individual employees who have been sus pected of having it. There have been potential exposures, however, which make it important that these men and other employees at King City have careful and continued surveillance. If there are questions, do not hesitate to write or call me. Sincerely, W. Clark Cooper, M.D: WCC/rw Enclosure 2180 Milvia Street, Berkeley. California 94704 Tel.: 41S/S4S-33SS REVIEW OF OCCUPATIONAL HEALTH PROGRAM AT THE KING CITY PLANT OF UNION CARBIDE CORPORATION (WITH EMPHASIS ON ASBESTOSIS) by W. Clark Cooper, M.D. Equitable Environmental Health, Inc. August 9, 1976 INTRODUCTION On June 30, 1976, at the request of John J. Welsh, M.D., Corporate Medical Director of Union Carbide Corporation, a visit was made to the King City plant to review the industrial hygiene and occupational medical program with particular reference to asbestos problems. A comprehensive review of the situation was provided by Mr. F. H. Larrison, Jr., who has been plant manager since 1971. Environmental data and medical summaries were made available. The plant was then toured in company with Mr. R. J. Cronkite. During the afternoon a visit was made to the Southern Monterey County Medical group, where selected medical re cords and films were reviewed with Dr. Duane F. Hyde. OBSERVATIONS The King City Asbestos plant, operated by the Mining and Metals Divisi of Union Carbide Corporation (local mailing address P.0. Box K, King City, CA 93930, telephone (408) 385-3209), has been in operation since 1963. A- It currently has 60-65 employees. It is located near U.S. Highway 101 on the outskirts of King City, a community with a population of about 3,000 in Monterey County, roughly 125 miles south of the San Francisco bay area. Its operations are limited to the processing of chrysotile asbestos, which is mined in San Diablo, about 55 miles east of the plant, and moved to King City by truck. Mining is carried out by contractors, over a six-month period May through October. There are three plant employees at the mine who operate a screener; they work in the processing plant when the mine is not in operation. The other employees are full time in the process ing plant, where activities include moving asbestos crude from outdoor stockpiles, through crushing, drying, separation, sizing, packing and loading. Industrial Hygiene. Industrial hygiene has been the responsibility of Mr. Paul McDaniel, the corporate industrial hygienist who is based in New York City. He visits the plant every 6 months. He set up the ori ginal industrial hygiene program when the plant opened, in September 1963, and has planned and supervised subsequent improvements necessitated by in creasingly rigorous standards. Originally the objective was to maintain a time-weighted average dust concentration of 5 million particles per cubic foot, by midget impinger. In 1968 the standard became 12 fibers/cc (greater than 5 urn in length); subsequently this was reduced to 5 fibers/cc. Until a more rigorous dust control program was inaugurated in 1972, there were a number of areas in the plant that exceeded the current standards. In 1969 there were fiber counts of 16 f/cc in the bagging area, and in 1971 2 counts were still quite high in the bagging and palletizing areas. In all of these high exposure areas, wearing of respirators was mandatory, and in the bagging and palletizing areas, air-supplied respirators were provided. The stricter dust controls which became operative in 1972 included enclosure of bagging areas, improved exhaust ventilation and spraying of all ore piles, in addition to greater emphasis on housekeeping. Since April 1973, clothing change areas have been provided. According to the plant manager, the plant has met all MESA and CAL-OSHA inspections since 1971. The highest timeweighted average for any operation since the new program began has been 4.73 f/ml. No attempt was made to evaluate the industrial hygiene activity at the time of my walk-through visit. It was obvious that the packing, palletizing, and loading operations provided the greatest potential dust exposures. Bulk loading also offered control problems; no loading was actually going on during my visit. Questions were raised regarding labelling of box-cars containing bulk asbestos. The Medical Program. The plant has had pre-employement and periodic examinations since it opened. Except for a brief period of time when these were done by a clinic in Salinas (21 miles north) they have been carried out in King City. The original program provided for examinations every 3 years for those up to 40 years of age, every 2 years for those 40 to 50, and annually for those aged 50 or more. Chest films have been taken annually. Beginning in 1973, annual pulmonary function determinations were added. 3 a i 1 (19 C Examinations are currently performed5by the Southern Monterey County Medical Group, 210 Canal Street, King City, CA 93930, phone (408)385-5471. The director is Duane F. Hyde, M.D.; Thomas M. Ashby, M.D. has been in charge of internal medicine, and films have been interpreted by Dr. Bryant. it Review of medical records. Concern had developed about possible asbestosis during recent months because of medical reports in four employees. Although not specifically diagnosed as asbestosis, the possibility of as bestos being a factor has been raised, and there have been recommendations that at least some of themen be removed from any further exposures. The medical records and chest roentgenograms of the four individuals were carefully reviewed. They can be summarized as follows: (1) Hire dates had been 1964, 1965, 1966 and 1971, so that as of late 1975, when questions of asbestos effects were being raised, possible exposure periods ranged from 4 to 11 years. This is very short for development of detectable changes in asbestos, unless exposures are quite heavy. (2) Chest films showed no abnormalities. (3) All of the four men had had some? periods of employment in areas with relatively high potential exposure. (4) Pulmonary function changes, (based on 9-liter Collins spirography) were the basis for diagnosing lung disease. In each of the men, the reported impairments where those of obstructive, not restrictive lung disease. In none did the pattern resemble those seen in asbestosis. The four were as follows: 4 4 1 <89 l (a) This man, employed in 1971, had the following note in his record. "This worker has shown consistent decrease in FEV, over past four years and is now abnormal. If he is a smoker he should quit. He is definitely a risk and a change in his exposures should be considered strongly." (He has ' smoked 20 a day for 8-9 years, plus 2 - 3 cigars/week.) Function tests showed decrease in one second forced expira tory volume (FEV]) of 4085 cc in 1974, to 3995 in 1975, to 3545 in 1976. Forced vital capacity (FVC) increased from 5175 cc to 5285 to 5505 in the same period. This is not consistent with any reported reaction to asbestos. (b) This individual, employed in 1966, had a medical report: "Indications of beginning obstructive lung disease. His vital capacity has risen every year which can be indicative of beginning emphysema." FEVi in December 1973 was 3425, November 1974 3870, December 1975 3725; corresponding FVCs were 4570, 5230 and 5475 cc. This individual had a history of asthma and allergies to house dust and had a cold at the time of his lowest FEV-j record. He was a non-smoker. Findings were not consistent with asbestosis. (c) A third worker who had been a mechanic, first employed in 1965, had an FEV-| of 4105 cc in 1974, reported as 2900 in 1975 (72% of predicted), rechecked as 2950 cc. Clinical note: "This record is consistent with pulmonary emphysema. Definite obstructive lung disease." His FVC was excellent, being 5290 cc and 5365 cc in 1974 and 1975 respectively (117% and 125% of predicted). He is a smoker of one pack a day for 20 years. Again, this is not the pattern of asbestosis. (d) The fourth individual had been hired in 1964, and was now working as a mechanic. His FEVi was reported as 4050 cc in 1973 4230 in 1974, and 3175 cc (78% of predicted) in November 1975. The note at this time was: "Has evidence of beginning obstruc tive lung disease, if a smoker should stop." Repeat examina tion in December, 1975 showed FEV] of 3725 cc (95% predicted). Forced vital capacity has been consistently above 100% of predic ted and has not been decreasing. No evidence of definite func tional abnormality. CONCLUSIONS 1. There was no radiographic, clinical or physiologic evidence to support a diagnosis of asbestosis in any of the four King City plant employees who had been reported as having evidence of impaired pulmonary 5 ventilatory function. 2. There is suggestive evidence of obstructive lung disease in two men, both of whom have histories of cigarette smoking. One would not be warranted in making final diagnoses, however, on the basis of limited spirography. 3. Exposures to asbestos, especially in bagging and palletizing operations, have been high enough in the past to produce some pulmonary effects if there was not strict adherance to respirator use, but one would not expect it to have produced either radiographic or functional evidence by this time. 4. The first functional changes to be detected using the tests em ployed at King City would be reduction in forced vital capacity (FVC). While obstruction in finer airways has also been reported, this would not appear as gross deviations in the forced expiratory volume (FEV). 5. The staff at the Southern Monterey County Medical Group is quite competent, and the clinic is well-equipped to do periodic examinations. Cur rent scheduling is adequate. However interpretation of medical information has been in the direction of overdiagnosis and undue concern based upon spirometric results. This is natural in view of the fear of liability for any consequences that might be attributed to asbestos or failure to warn a worker of any suggestion of functional impairment, but needs to be balanced by realistic consideration of actual exposures and economic and psychologic im pact on the workers. RECOMMENDATIONS 1. If the four individuals in question consistently show reduced 6 A 1 1893 ventilatory rest results they should have complete clinical and laboratory evaluations with more sophisticated and complete testing to define their functional capacities. 2. Annual examinations should be continued on all production employees exposed to asbestos, in conformity with current regulations. There should be a standard history form to be sure that there is adequate information on past occupational exposures, smoking history and record of respiratory dis eases and symptoms, t A test for occult blood in stool should be included in examinations for those employed for over 10 years. 3. Each worker, regardless of findings or the duration of employment should have an interview with the examining physician after his annual ex amination. He should be shown his chest film and given a report on pul monary function, and provided guidance on health protection, including dust avoidance and cessation of cigarette smoking. 4. There is no need for routine sputum cytologic examination at this time._ 5. Records and films of all individuals who have worked for 5 or more years in the King City plant should be reviewed annually by a consul tant experienced in asbestos-related disease, who should provide a brief note for each record. 6. The physicians in King City should be supplied with more adequate information on asbestosis and its diagnosis and should be familiar with the plant's industrial hygiene program. 7 l\1 1894 7. Employees at the King City plant probably need a more thorough educational program on asbestos, its hazards, and how to protect themselves. 8. Preparations should be made for the lowering of the occupational standard for asbestos to 2 fibers/cc and the probable lowering to 0.5 fibers/cc. The cost of the necessary changes must be carefully weighed when considering the feasibility of continuing the King City operation. There is evidence, largely from Canada, that exposures to chrysotile as bestos during mining and milling are not associated with as great a risk of lung cancer and mesotheliomia as is found during the use of products containing chrysotile, such as insulating material. The proof of this lower risk is not universally accepted, however, and plays no part in current standard-setting. One must assume that employees at King City who have worked where their time-weighted average exposures exceeded 5 f/cc or where peaks exceeded 10 fibers/cc on a regular basis, if un protected by respirators, will eventually show some excess of lung cancer. This would not be expected until the late 1980's. However, I would not expect current exposures to produce detectable excess cancer mortality. If such did occur it would not be apparent until near the year 2000. Dis abling asbestosis, i.e. pulmonary fibrosis, from exposures such as have been present at King City is extremely unlikely. 8 A 1189b