Document qayqpmvJEMbv24bNQzJ8Q2o7R

PRIVILEGED & CONFIDENTIAL DRAFT: June 22, 1984 TESTIMONY OF ROBERT J. BETTACCHI My name is Robert J. Bettacchi. I am Vice President for Marketing and New Business Development in the Construction Products Division of W. R. Grace & Co. I have worked in the building products industry since 1979, in both research and marketing roles. I am appearing today on behalf of the Alliance for Safe Buildings which was recently formed to help deal with the public issues concerning asbestos-containing materials in schools and other buildings. The Alliance is composed of companies who have in the past supplied products containing asbestos for use in building construction. As such, we are specially concerned about asbestos-containing materials found in schools and other buildings. The Alliance is not concerned with current manufac ture and use of asbestos-containing materials. The members of the Alliance, as individual companies, have followed EPA's activities regarding asbestos in schools for many years. These companies have generally been supportive of EPA's early Technical Assistance Program. The initial Program did an effective, well-balanced job of providing necessary guidance to local school administrators. Unfortunately, the March 1983 revised guidance document has a number of flaws which, when combined with EPA's recent enforcement and publicity efforts regarding the inspection and notification rule, have created a serious and hazardous situation in many loca'i school districts. V 0635196 -2Therefore, the Alliance is supportive of EPA's decision to revisit the issue of asbestos in schools and encourages the Agency to take a comprehensive, yet prompt look at the current situation. The Alliance hopes that the Agency will make a reasoned judgment based on the best available information. We are testifying to support the adoption of a sensible policy to respond to any conditions that present an unreasonable risk to building occupants. We are also concerned that precipitous action could actually exacerbate the risk from asbestos-containing products in buildings. It is important that EPA work closely with local school dis tricts to evaluate the nature of any asbestos hazard in school buildings and to assist in response actions where necessary. To date, however, EPA's program has faced several difficulties-that now require correction. Most importantly, the Agency has not adequately distinguished between those conditions that are reasonably safe and those requiring abatement action. In the absence of such further guidance, we will continue to risk unnecessary and precipitous asbestos removal actions that are both costly and dangerous, while at the same time truly hazardous' situations may go uncorrected. We further believe that EPA should first concentrate its resources on the complex schools questions before examining the broader, even more complex, question of asbestos-containing materials in other buildings. To help EPA improve upon its program, the Alliance has asked two top national experts to assist the Agency. After i 0635197 -3reviewing the record compiled to date, the Alliance decided to present two witnesses. Dr. Kenny S. Crump and Dr. Robert Sawyer, not because our member companies necessarily agree with every thing they may say here today, or in other forums. Instead, we asked them to appear here today because they are among the world's foremost experts on the issues that EPA must address, including specifically the risks that may be presented by asbestos in schools and other buildings and on possible corrective actions that should be taken. The Alliance will file detailed written comments with the Agency in early July. Our first witness today is Dr. Kenny S. Crump, who has extensive education and experience in critiquing and prepar ing quantitative risk assessments. Dr. Crump earned a Ph.D. in mathematics from Montana State University in 1968 and was a Professor of Mathematics from 1966 to 1980 at Louisiana Tech University. In 1974 and 1975 he was a visiting scientist at the National Institute of Environmental Health Sciences (NIEHS). Since 1978, he has been the President of K. S. Crump and Com pany in Ruston, Louisiana. Dr. Crump has also authored numerous articles in refereed scientific publications, particularly on issues relating to quantitative risk assessment. He has frequently consulted with and prepared reports for many government agencies, including NIEHS, the Environmental Protection Agency, the Council on Environ mental Quality, and the Congressional Office of Technology Assessment, as well as for a number of private industry groups. 04331 -4Dr. Crump also served as a member of several National Academy of Science panels, including the panel that last year issued the report, "Risk Assessment in the Federal Government: Manag ing the Process." He has developed several risk assessments for the Occupational Safety and Health Administration (OSHA) on workplace exposure to arsenic and to ethylene oxide. ***** Thank you Dr. Crump. Our second witness is Robert N. Sawyer, M.D. Dr. Sawyer earned an undergraduate degree in engineering studies at the Massachusetts Institute of Technology in 1956, a Doctor of Medicine at Western Reserve University in 1963, and a Masters of Public Health degree at the Yale School of Medicine, Department of Epidemiology and Public Health in 1970. He is Board certified in preventive medicine and a fellow in the American College of Preventive Medicine. He is currently a Lecturer at the Mt. Sinai School of Medicine, Laboratory of Environmental Medicine, and an Adjunct Assistant Professor in the Department of Medicine at the University of Pennsylvania. Dr. Sawyer also serves as Vice President of Environmental Technology, Inc. of West Hartford, Connecticut, consultants in environmental sciences and industrial medicine problems. Much of this firm's consulting work involves asbestos in buildings. This has included, over the years since 1978, an estimated 2,000 evaluations of asbestos contamination potential in buildings, 0^33199 -5structures, and vessels in six countries and throughout the United States. As listed in his curriculum vitae. Dr. Sawyer has also authored articles in various scientific publications, many relating to asbestos exposure within buildings. He has con sulted with EPA and has also contributed to the National Academy of Science National Research Council report on Indoor Pollu tants. Dr. Sawyer is also a member of the New York Academy of Science, the American Academy for the Advancement of Science and the American Occupational Medicine Association.