Document qaKQXYoa1kVdmLXZeMw57m08G

lienor; WAT-atAU ' institute, inc., s-210 m 4, pa^aws, n. d. 07652 duly 17, 197$ To: Asbestos Study DormiKes Su^jectt Hens of interest to Committee THE 2 FISEfVCC L.UT AMP ttH3RAK HITS* KETHPP At the April 2S, 1975 ccrr.mi\tee meet ing, e resolution was osssed: RcSCtVEIb Thai fh- Co.-rcnjHee reguests guidance from the Hoard of Directors concerning the problem of the 2 ffber/cc limit and the lack of re liability of the membrane filter method for measurement of fibec counts. This resolution was discussed at the dkjne 17, 1975 meeting of the 3ua. d of Directors. . Qjoiai ions from a draft copy of (h minutes of that Board of Directors meeting follow: At this point it was stated that the Asbestos Study Cosmuitee had passed a resolution a.s follows! rtThat the Conroitiee requests guidance from the Board of Directors concerning the problem of the two Hber/cc limit end the X&ck of reliability of the membrane fiHer method for measurement of fiber counts," The Asbestos Study Committee members v/ere concerned that while the membrane filter technique is the only method now available for measuring asbestos concentrations it is a most unreiisb? tool for enforcement of the two fibers/ce limit. M searching for guidance for the Committee one Director stated thet our objection to use this method for enforcement would net be construct ive. ft would just stir ratters up without providing an alternative. Come regulatory authorities are receptive where suggestions are trade for improvement. Simply indicating our diseatisfaciion wilth the membrane filter method fer enforcement might be considered as e negative attitude. - Director stated that the hygienists will use cersncn sense and realize the fallibility of the membrane filter technique. It is fairly well k~own'sn industry end government that this technique fallible. While the directors expressed concern over the use of (his as sn enforcement tool, they do net feel that any institute position should be expressed to OSHA concern ing its use. K was felt that these enforce in? the OSHA regulations are eware of the disrariry i* using this i schri-cue. th' s point !>. &2\r\ of the FchR'< indicated that work had been done in curcos concerning sampling and countin$. He said that hi asbestos association Chambre SynqTcale de 1 ' A-nf&nte (franc), had an expert working fon the association in the tempi ing and counting . area. Members exchange slides and see how the counts come out. HIs *'/aitjnc for a resort on this study. It *23 suggested that there is no other means of measuring the asbestos concentration and it is most likelv CSHk will stav with this method regardless of ary input F- VW-06145 -2 v Sr? summary, the Erectors sjrgu^ied that no action be taken a* regards membrane filter method and its use for ofor cement of the Z fiber?cc J on Jjly 1, 1*76, On iAme 24, 1975, 0$NA published proposed rules for N10SH j nvesiigst daces of employment. OSMA states that the proposed amendments are to cover procedures that have informally been utilized by NlCSK ssm of the OSi# Act and that no additional burdsn is placed on employer A copy of this notice as it appeared in the federal Register is ent Enclosure-* s. &\ Drislane Executive Director