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November 22, 1977 Mr. Lewis B. Weisfeld Cincinnati Milacron 4701 Marburg Avenue Cincinnati, OH 45209 Dear Mr. Weisfeld: Five (5) copies of the complete text of the paper I presented at the recent Denver meeting are enclosed. We would like to request that it be considered for publication in one of the Society of Plastics Engineers journals. It was a pleasure to appear on your program and I enjoyed the meeting very much. Very truly yours, Harrison B. Rhodes Manager - Technology HBR/rmm Encs. BCC: Messrs. J. F. Collins T. W. Carmody R. F. X. Fusaro J. L. Myers C. Thurber This is the final edited version. The talk presented was abstracted from this. rttCElVED NOV 2 8 1977 UCC 018212 CONSUMER "SAFETY" IN PLASTICS SYSTEMS CONTAINING BOUND ASBESTOS FIBERS Harrison B. Rhodes, Ph.D. Technology Manager "Calidria" Asbestos UNION CARBIDE CORPORATION Metals Division Niagara Falls, New York November 9, 1977 UCC 018213 ABSTRACT Asbestos consumption in the United States in 1976 was 726,000 tons, mostly chrysotile. Of this total, 65% was used in a wide variety of plasticsbased materials. Extensive airborne asbestos exposure data are presented for tape joint compounds, roofing products, and coatings. The highest consumer exposure found was 1.2 fibers/cc ceiling and only several tenths of a fiber/cc on a time-weighted average basis. A risk estimation procedure devised by the Consumer Product Safety Commission was used to calculate the risk to the consumer from these highest levels measured,which occurred during drywall installation. The risk was found to be only very slightly different from zero, but the CPSC is moving to ban asbestos in this application on the basis of a regulatory philosophy of "no safe level for a carcinogen" and "absolute zero risk" as an appropriate regulatory policy. The consequences of this regulatory approach are discussed and an alternative is proposed. UCC 018214 TABLE OF CONTENTS Section INTRODUCTION ASBESTOS USE IN THE UNITED STATES AIRBORNE ASBESTOS EXPOSURE - PLASTICS PRODUCTS Sample Collection and Counting Procedure Asbestos Exposure - Tape-Joint Compounds Asbestos Exposure - Roofing Compounds Asbestos Exposure - Coatings, Compounds, and Plastics CONSUMER SAFETY REGULATORY ACTIONS SUMMARY AND CONCLUSIONS REFERENCES FIGURES TABULAR DATA Page 1 1 3 3 5 10 10 12 14 16 18 19 22 UCC 018215 INTRODUCTION In view of the wide publicity that has been given to the health hazards of asbestos, both real and imagined, over the past ten years, it may come as a surprise to many that asbestos is still in wide use, and more of a surprise that anyone is willing to write about it. In fact, over 700,000 tons of asbestos are used annually and much of it is in various plastics-based systems. This paper will touch briefly on the kinds of plastics products which contain asbestos and the quantities of asbestos used in these products. Results of airborne asbestos fiber measurements during the use of a wide variety of asbestos-containing plastics materials will be presented. The data are mostly for commercial operations but substantial consumer-use information is provided for one product. A risk assessment procedure currently favored by the Consumer Product Safety Commission will be used to calculate the consumer risk from the exposure levels found. This risk will be related to the current governmental regulatory philosophies. The consequences of these philosophies are discussed, and a rational approach to the overall problem is suggested. ASBESTOS USE IN THE UNITED STATES As shown in Table 1^, about 726,000 tons of asbestos, mostly chrysotile, were used in this country in 1976. Of this, approximately 125,000 tons were from domestic production, largely from California and Vermont, and the remainder was imported,primarily from Canada. If the term "plastics" is defined broadly to include naturally occurring tars, resins, and other materials that cure to a permanent set, as well as the usual synthetics, a total of 472,000 tons of asbestos,or 65% of the annual consumption, is associated with "plastics" of one kind or another. The product areas that make up this total are indicated by arrows on Table I. The largest use, 253,600 tons, is in roofing products, largely asphaltic-based,but some epoxy is used in the high-performance products. UCC 018216 Included in this group are emulsified coatings, trowel able patching compounds, and some tar papers. The next largest application is 113,500 tons in flooring products, including both vinyl asbestos tile and sheet vinyl flooring. This is followed by friction products at 63,800 tons, used primarily in phenolicbased materials for automotive and railroad brakes and for clutch facings. The list concludes with the Plastics and Coatings and Compounds categories at about 20,000 tons each. These include a wide variety of products such as the familiar phenolic-based electrical fixtures, anthophyllitefilled polypropylene for heat-sensitive applications, maintenance coatings, block coatings, foundation coatings, automotive undercoatings and sound deadeners, caulks, sealants, adhesives, tape-joint compounds, and so forth. It is clear that there continues to be a very substantial involvement of asbestos with plastics and that about half of it is with the familiar vinyl, phenolic, alkyd, and epoxy resins. The specific reasons for the inclusion of asbestos in each of these product types varies but is generally related to several of the important properties of this material. Asbestos is inert, "fireproof" or heat resistant, and imparts strength and dimensional stability to plastics both at ambient conditions and when subjected to high temperatures. These properties are particularly important for friction products. The strength plus resistance to mildew, rot, and weathering are important for roofing and flooring materials. When used in small quantities in liquid systems, asbestos has a profound effect on rheological properties. It makes the materials sprayable or pumpable but sag resistant after application. Examples of this include flow control of paints and coatings, trowel workability of tape-joint compounds, and the flow of caulks and sealants during application. The fact that asbestos is in wide use after six years of stringent regulations and tremendous adverse publicity -2- UCC 018217 attests to its value and to the difficulty of finding suitable replacements which are safe and/or not regulated. AIRBORNE ASBESTOS EXPOSURE - PLASTICS PRODUCTS The Union Carbide Corporation, in 1963, initiated commercial mining and milling of a short fiber asbestos from a unique deposit in central California. This material is sold only as fiber and no asbestos-containing products are manufactured. In the "plastics" applications categorized previously in Table I, this asbestos is used in flooring products, roofing products, in a variety of coatings, in compounds and in some plastics. It is not used in friction products. Monitoring has been conducted at the asbestos plant since 1963; and, in 1972, the Corporation initiated an asbestos dust monitoring service to assist the product users to provide a safe and healthful workplace for their employees and to comply with the applicable governmental regulations. The data to be presented here were obtained as part of this program. Unless otherwise noted, all of the samples were collected under field conditions during normal and routine operations. Sample Collecting and Counting Procedure Sample collection and fiber counting were carried out in accordance with (2) the prescribed NIOSH procedure ' in effect at the time of collection. Since this procedure is described in detail by NIOSH, it is only necessary to touch on it briefly* Samples were collected on 37 mm. Mi Hi pore AA filters (0.8y porosity) with small MSA battery-driven vacuum pumps. Figure 1 shows two consumers wearing pumps and filters. The filter cassette is attached in the collar area of the worker so that it is suspended facing downward in his -3UCC 018218 breathing zone. The pump draws the dust-laden air through the filter and dust is deposited on the filter paper. Only data from such personal samples are reported. For fiber counting, a pie-shaped wedge is cut from the filter, mounted on a slide with the prescribed clearing solution, and the fibers are counted at 400X with a Nikon microscope with Huygenian eyepieces. A Porton reticle is used for field definition. The NIOSH procedure was originally developed to measure airborne dust concentrations where asbestos was the principle constituent. The ability of this procedure to distinguish between asbestos and other particulates of the prescribed dimensions is quite limited and well recognized('3) This lack of definition presents particular problems in the present study. Many of the samples were generated by spraying or by abrasion of plastics materials containing other mineral ingredients besides asbestos: fiberglass, mica, various clays, fibrous talc, mineral wool, etc. The NIOSH procedure permits the use of "other information" to avoid counting non-asbestos fibers but does not specify the nature of such information or how it is to be used. The Union Carbide laboratory collects bulk samples of known materials wherever practicable and maintains a "library" of reference samples and photographs. Scanning electron microscopy is also used to a limited extent. All fibrous particles meeting the NIOSH criteria of length greater than 5y and aspect ratio greater than 3 are counted as asbestos fibers unless an experienced counter can recognize them with a high level of confidence as not being asbestos. This criterion was used for all of the Union Carbide data reported herein. -4- UCC 018219 Asbestos Exposure - Tape-Joint Compounds The largest body of asbestos exposure data available is for the installation of drywall with tape-joint compound. The drywall system consists of gypsum board, usually 4 feet long and 8 feet wide, manufactured with a small beveled depression about 4-inches wide on the long edges of the sides to be finished. For installation, the boards are first nailed to the studding, compound or "mud" is applied to the joints, and paper tape about 2" wide is buried in the mud. The nail holes on other parts of the board are also filled with compound. After the initial coat t is dry, a second coat is applied. When this is dry it is sanded, generally lightly to remove high spots and a finish coat of mud is applied. After drying this is sanded if a smooth wall finish is desired, or left "as is" if the wall is to be textured. The taping compound or mud is made up primarily of finely-ground limestone with lesser amounts of mica, clay, and asbestos. A representative formulation for ready-mix is shown below. The asbestos content typically ranges from 2-5% by weight on a dry basis. The binder is vinyl-acetate latex, starch, casein, or polyvinyl alcohol. The compound is available as a dry powder which must be added to water at the time of use, or as a ready-mix which can be used with no preparation. COMPOSITION OF TYPICAL READY-MIX TJC INGREDIENT WATER LIMESTONE MICA (AND CLAY) BINDER ASBESTOS MISCELLANEOUS PERCENT BY WEIGHT WET BASIS DRY BASIS 31 -- ' '41 60 16 23 7 10 34 23 100 100 -5- UCC 018220 shown graphically in Figures 2 and 3 . Figure 2 gives the airborne asbestos fiber concentrations measured during the actual sanding operations. The commercial operations are on the left, and the consumer uses on the far right. The type of sanding, i.e, hand or pole, and the number of samples included in the average are indicated along the horizontal axis. The data on the far left are those of Rohl et al'^ . Their results range basically from about 1 to 20 fibers/cc >5y with averages of 10.0 and 5.3 fibers/cc >5yi for pole and hand sanding, respectively. The next group of results are those obtained by Union Carbide in the survey of commercial operations in six different cities. Results range from about 0.2 to about 4 fibers/cc. The range found corresponds reasonably with the intensity of sanding, the room size and ventilation conditions, and the number of men operating in the same room. This reference also includes measurement of respirable dust and crystalline silica,which follow the same patterns as the asbestos, and may be of general interest. The OSHA compliance and Equitable Environmental Health^ data are shown next. These fiber concentrations fall in the same range as the results just discussed. -------- The consumer-use data are shown on the far right. The first case is for the extensive spackling and the installation of three panels of drywall. The second is for the three walls and the ceiling of a large basement recreation room. This latter mud contained 2.6% asbestos by weight on a dry basis. Exposures in these tests were only 0.2 to 1.2 fibers/cc >5y, which correspond roughly to the lower end of the range found for commercial use. Data for the two other operations in tape-joint installation which present the possibility of exposure to free-form asbestos fiber, i.e, the addition of the dry powder compound to water and the cleanup after sanding, are shown in Figure 3 . -7UCC 018222 Here, in order to get the Rohl et al data on the graph, it was necessary to run the scale from zero to sixty rather than from zero to twenty as in the previous Figure. Otherwise, the graph follows the same format and shows a very similar pattern. The Rohl et al(v41' data are far higher than the OSHA results, and the consumer values are below or in the lower end of the range found for commercial use. When the large differences between the Rohl and Union Carbide studies first became apparent,fiIters from three of the Union Carbide locations were counted "blind" by two other laboratories. The results shown in the next table demonstrate that the differences were not due to improper counting by the authors of that work. INTERLABORATORY COMPARISON ASBESTOS FIBER COUNTS^ Sample Source Location I 1 * (Filter 1) (Filter 2) Location 11 (Filter 1) tl (Filler 2) Location 111 (Fi1 ter f1) It (Fi1 ter 2) Airborne Asbestos Fiber Concentration (ribers/cc lonfjer than Sum) By UCC By Ub A By Lab B 0.4 0.4 . 0.3 0.0 0.2 0.2 1.5 1.0 1.3 1.0 1.6 0.6 0.6 0.0 0.4 0.2 0.9 0.2 Unfortunately, Rohl provides no details on the nature of the operation sampled, i.e., whether it was run as a specific test.or as the sampling'of a routine commercial installation, the asbestos content of the mud, the number of men sanding in a room, the size of the room or rooms sanded, or the presence or lack of ventilation. There is no way to evaluate the influence of the specifi test conditions on the results reported or to determine how they may relate to other commercial operations. The tests also appear to cover a total sanding time of no more than 15 minutes for pole sanding and about the same time for -8UCC 018223 hand sanding. It can be questioned whether this is a representative sample of commercial operations but there is insufficient information to really explain the differences. The concentrations just described were obtained during the actual dust generating operations. In virtually all cases, even the commercial operators do not engage in these operations for a full shift so that the 8-hour time- . weighted average will be considerably less than the exposure while dust is being generated. Values for the sanding conditions in the study by Rhodes and Ingalls^ and the 8-hour time-weighted averages are shown in the following table. The results ranged from 0.1 f/cc >5p to the highest value of 0.9 f/cc >5y. SUMMARY OF AIRBORNE ASBESTOS FIBER CONCENTRATIONS DURING DRYWALL SANDING^ location Hew York City, KY Hialeah, Ft Ft. Lauderdale, Ft (Hand) Detroit, HI Dallas, TX Ft. Lauderdale, Ft (Pole) Niagara Tails, NY Ceiling Exposure (Fibers/cc >S;.ro) 0.4 1.0 1.1 1.3 1.8 3.4 3.6 Cxpusurc 1 i me During Sanding (HoursL 8.0 4.0 1.0 8.0 0.5 3.3 0.6 - Estimated C-Hour TWA Exposure (Fibcrs/cc 0.3 0.4 0.1 0.9 0.1 0.6 0.2 Eight-hour time-weighted average exposures have also been calculated for the two consumer installations and the highest exposure found was 0.2 fiber/cc >5p for two days while asbestos-containing dust was being generated. In general it appears, therefore, that consumer operations may be characterized with ceiling exposures in the order of 1-2 fibers/cc >5y and eight-hour time-weighted average exposures of several tenths of a fiber/cc >5p. -9- UCC 018224 Asbestos Exposure - Roofing Compounds It was shown in Table I that about 253,600 tons of asbestos are used annually in asphaltic-based roofing compounds. The asbestos is an important ingredient in emulsified and cut-back coatings, trowelable patching and sealing compounds and in some tar papers. It is not used in hot-melt roof coatings. Data for the spraying of emulsified and cut-back asphaltic coatings is shown in Table VIII. Similar data that include both rip-off and installation of built-up roofs with asbestos-containing materials are shown in Table IX. These data were presented by the Flintkote Company and Johns-Manville Corporation, respectively, in response to an EPA proposal^ to change the current Asbestos National Emission Stnadard for spraying of asbestos-containing materials. The results from eight field locations and one test sequence ranged from 0.0 to 0.6 fibers/cc >5y and averaged 0.1 fibers/cc >5y. Asbestos Exposure - Coatings Compounds, and Plastics These categories encompass a myriad of products consuming about 41 ,400 tons of asbestos annually. Typical examples include high-performance maintenance coatings, special purpose trade paints such as block coatings, caulks, sealants, adhesives, and certain laminating resins. In these products the asbestos functions primarily as a rheological agent and is usually present in small quantities such as 0.5-3% and seldom exceeds 5% by weight. Some of these products are normally applied by spraying and those based on thermoset resins may in some cases be subject to abrasion during finishing or in the process of subsequent removal. ,# Data on the airborne asbestos levels during the spraying of nine different systems at twelve locations are provided in Tables X and XI and are summarized in the following table: -10UCC 018225 SPRAYING OF COATINGS AND RESINS CONTAINING ASBESTOS EPOXY AND EPOXY-COAL TAR COATINGS WT. % ASBESTOS 1 - 1.5 CHEMICAL-RESISTANT POLYESTER COATING 0.7 - 1.4 VINYL AND ALKYD COATINGS 1.1 - 6.0 VINYL AND ACRYLIC LATEX COATING 0.7 - 3.7 POLYESTER LAMINATING RESIN 0.5 0.5 - 6 NO. OF LOCATIONS 3 2 2 2 3 12 NO. OF SAMPLES 5 5 6 4 7 27 AIRBORNE ASBESTOS CONCENTRATION (FIBERS/CC >5u) RANGE AVERAGE 0.0 - 0.2 0.1 0.0 - 0.4 0.3 0.0 - 0.04 0.03 0.0 - 0.2 0.05 0.0 - 0.6 0.0 - 0.6 0.2 0.15 The highest asbestos content in the resins examined was 6%,with values in the 0.5 - 3% range much more common. Fiber counts ranged from 0.0 to 0.6 fibers/cc >5y. It should be noted that the highest values occurred during the simultaneous use of fiberglass with a "chopper" gun,and fiberglass chips undoubtedly made a substantial contribution to the "asbestos" total reported. Data for the sanding of polyester laminating resin and a vinyl latex paint are shown in Table XII and are summarized in the following table: -11- UCC 018226 SANDING AND GRINDING OF RESINS CONTAINING ASBESTOS APPLICATION WT. % ASBESTOS NO. OF LOCATIONS NO. OF SAMPLES AIRBORNE ASBESTOS CONCENTRATION (FIBERS/CC >5u) RANGE AVERAGE POLYESTER LAMINATING RESINS 0.5 - 3 5 12 0.0 - 0.4 0.2 VINYL LATEX COATING 1.1 1 4 0.0 - 0.3 0.1 0.5 - 3 6 16 0.0 - 0.4 0.15 Results for six locations ranged from 0.0 to 0.4 fibers/cc >5y and averaged 0.16 fibers/cc >5y. Here, too, there were counting problems due to unidentifiabl particles of non-asbestos material being included in the reported asbestos count. CONSUMER SAFETY Next it is desirable to consider how much risk the levels of exposure just described pose to the consumer. It is important to recognize, first of all, that consumer exposure is quite different from that encountered by the worker who is manufacturing a product or the professional who installs it. These workers are exposed to the level of airborne fiber characteristic of their particular operation for a full working day over extended time periods up to a full working lifetime. The consumer, on the other hand, may have a brief exposure while the particular product is being used and spend the rest of his life without measurable exposure from the particular item. Basically, the evaluation of risk involves the selection of a model, calibration of the model with the epidemiological data that is available which, incidentally, is usually at high and poorly defined exposures, and then extrapo lation to predict the effects of very low exposure levels. The results are very -12- UCC 018227 sensitive to the model chosen and there is widespread disagreement among workers in this field. The best known correlation and extrapolation procedure for the risk of lung cancer from asbestos exposure is that of Enterline and Henderson These authors carefully list the eight assumptions upon which the model is based. Since the Enterline correlation deals mainly with continuous exposure, Dr. Steven (a) Bayard' ' of the Consumer Products Safety Commission, modified the approach to apply to occasional exposures. He introduces an additional assumption that the effect of dose is cumulative. This builds a geometric increase in risk into the model which can be seriously questioned, but this is not the place to debate the issue. The Bayard modification has been used here to calculate cumulative risk for periods of 40 and 100 years from onset of exposure for the consumer exposure levels reported here and for exposures of 1 fiber/cc >5y for two days. The latter level is about the same as the highest level found for commercial operations by Rhodes and Ingalls('5)\ The results are summarized below: RISK FROM CONSUMER EXPOSURE DURING OPERATIONS ANNUAL EXPOSURE (FIBERS/CC/YEAR) MEAN LATENT PERIOD TO TUMOR (YEARS) 0.2 FIBERS/CC FOR TWO 8-HOUR DAYS 0.004 621 ' 1 FIBERS/CC FOR TWO 8-HOUR DAYS 0.02 288 CALCULATED ASBESTOS-INDUCED RESPIRATORY CANCER DEATHS/MILL I ON 40 Years too years >0.00001 0.00014 0.00022 1.8 -13UCC 018228 The highest time-weighted average of 0.2 fibers/cc for two days found for the consumer application gives an annual exposure of 0.004 fibers/cc per day for one year, a mean latent period to tumor of 621 years, and something less than 0.00001 deaths per million of population from asbestos-induced cancer in a 40-year period after exposure. If the period examined is extended to 100 years, the number of deaths per million population predicted would be 0.00014, which is obviously still far less than a single death. The corresponding values for the 1 fiber/cc assumption are 288 years median time to tumor, a risk estimate of 0.00022 deaths per million over a 40-year period, and 1.8 deaths per million over a 100-year time span. For the roofing application, it seems very likely that the occurence of roof spraying by consumers is extremely rare since special equipment is required. The removal of old built-up roofing and replacement with new tar paper and trowelable emulsions by the consumer is undoubtedly quite common. The commercial data available indicates that exposures during installation would be substantially below those for tape-joint compounds, but quite possibly would still be detectable. The situation for the various coating and laminating resins is similar. While the consumer may not have access to many of these products, it is possible that he may occasionally sand certain of the coatings and finished products. In these cases a low, but still not zero, exposure to fiber can occur. In both of these cases the estimated risks will be well below the corresponding values for tape-joint compounds. REGULATORY ACTIONS Regardless of the exposures found for the use of tape-joint compounds and the risks predicted therefrom, the Consumer Product Safety Commission is proceeding to ban the use of asbestos for this application. This is true even though the product has been in widespread use for over 35 years and it has not been implicated in a single case of cancer in a consumer. More importantly, the CPSC is very -14- UCC 018229 actively looking for other asbestos-containing products that will be subjected to the same kind of treatment. The rationale for this action can be found in a philosophy which is very popular with most of the regulatory agencies today. This philosophy has two key elements: 1. A single molecule of a carcinogen (or a single fiber of asbestos)is capable of causing cancer in the rare person who is particularly susceptible. This leads to the general statement that there is no * absolutely safe or "threshold" exposure level for a carcinogen. 2. A zero level of risk is an appropriate regulatory goal. The first of these is ostensibly a scientific concept. However, until the background level of cancer from unidentified sources is eliminated or the mechanism of induction of cancer is fully understood, this concept can neither be proven nor disproven. Today it is, at best, a very controversial hypothesis and its use in regulatory matters is a policy rather than a scientific decision. The second is clearly a socio-political question:"How much risk from what sources is society willing To accept?11 Extensive application of the zero risk criteria by the CPSC and other agencies to the more than 2000 suspected carcinogens will have a massive and chaotic impact on our way of life. A more rational approach is urgently needed and we would like to suggest considerati of the concept described most lucidly in a recent book by Lowrance^^. In this reference "safe" is defined as: "A thing is safe if its risks are found to be acceptable." The risks are assessed and are then balanced against the benefits to society to serve as a basis for a decision on where it is appropriate to use the product. The balancing of risks and benefits is admittedly a difficult and controversial activity, but there is really no alternative. There is much that needs to be -15- UCC 018230 done to protect the worker on the job and the public at large. An emotion-driven zero risk approach will be self-defeating in the long run and possibly in the short run as the Saccharin controversy suggests. Awareness, concern, and constructive rational action, not emotion,are urgently needed. SUMMARY AND CONCLUSIONS Asbestos consumption in the United States in 1976 was about 726,000 tons, mostly chrysotile. Of this total 472,000 tons, or 65% of the total, were used in asphaltic or synthetic plastics-based materials. The largest use was roofing products at 253,600 tons followed by flooring products at 113,500 tons, friction products at 63,800 tons, and coatings, compounds and plastics at a total of about 40,000 tons. Extensive airborne asbestos exposure data for both commercial and consumer use of one plastics-based material, tape-joint compound, were presented. The consumer results show a short-term peak exposure of 1 - 2 fibers/cc >5y and an 8-hour time-weighted average of several tenths of a fiber/cc >5 y . Such exposures can be expected to occur for only several days out of a lifetime so that their effect on a person's overall exposure cannot be distinguished from the naturally occurring background. Data for exposures during the commercial use of roofing materials and during spraying and abrasion of a variety of coatings showed levels which were substantially below those for tape-joint compounds. Consumer exposures for the few of these products adaptable for consumer use is expected to be considerably lower than the commercial operations but are quite possibly still distinguishable from background during the time the product is actually in use. -16UCC 018231 Risk from this level of exposure was estimated using a procedure developed by the Consumer Product Safety Commission and was found to be only slightly different from zero. In spite of this, the CPSC is moving ahead with a ban on asbestos in tape-joint compounds and is actively looking for other asbestoscontaining products for the same treatment. The rationale for this action is found in dual policy decisions that there is no safe level for a carcinogen and that an absolutely zero level of risk is an appropriate regulatory approach. Extensive application of this approach to the more than 2000 carcinogens now suspected will have a massive and chaotic impact on our way of life. A more rational, realistic and workable approach where risk is balanced against benefits is suggested. -17UCC 018232 REFERENCES 1. Clifton, R.A., Asbestos-1977, U.S. Department of the Interior, Bureau of Mines, 1977. 2. NIOSH, Analytical Method, P & CAM 239, Nov. 1975, March 30, 1976, March 30, 1977. 3. LaFleur, P.D. et al. "A Report on the Fiber Content of Eighty Industrial Talc Samples", National Bureau of Standards, Washington, D.C., May 1977. 4. Rohl, A.N., Langer, A.M., Selikoff, I.J., and Nicholoson, W.J., Science, Volume 189, August 15, 1975, pp. 552. 5. Rhodes, H.B., and Ingalls, B.L., GDCI Drywall, January/February 1976. 6. Personal communication from Mr. Ken Dow, 1977. 7. 42 CFR No. 41, pp. 12122, March 2, 1977. 8. Enterline, P. and Henderson, V., I0EH Newsletter No. 51, Enclosure 9. Presented at Conference on Problems of Extrapolating the Results of Laboratory Animal Data to Men and Extrapolating the Results from High Dose Level Experiments to Low Dose Level Exposure, Pinehurst, North Carolina, March 12, 1976. 9. Bayard, S., CPSC Memorandum to Don Clay dated June 3, 1977. 10. Lowrance, W.W., Of Acceptable Risk, William Kaufmann, Inc., Los Altos, CA, 1976, pp. 8. -18- UCC 018233 ssur1 FIGURE 1 -19- UCC 018234 COMMERCIAL OPERATIONS-------------------------------------------------------------------------- : "+ CONSUMER USE I 9> ^4 M (4 FIGURE 2 - 20 - UCC 018235 AIRBORNE ASBESTOS FIBER CONCENTRATION DURING SANDING (FIbers/cc longer than 5 micrometers) *4 CD TYPE: HAND OR POLE NO. OF SAMPLES TAKEN WET-OUT OF DRY MATERIALS 60 55 50 45 40 35 30 25 20 15 10 5 0 2 5 SWEEPIMG AMO CLEAMUP AFTER SANDIN'G 2 13 4 FIGURE 3 -21- UCC 018236 NUMBER OF SAMPLES UCC 018237 ASBESTOS CEMENT PIPE ASBESTOS CEMENT SHEET ----------- FLOORING PRODUCTS --------- ROOFING PRODUCTS PACKING AND GASKETS INSULATION, THERMAL ' INSULATION, ELECTRICAL ---------- ^FRICTION PRODUCTS ----------- COATINGS AND COMPOUNDS --;----- PLASTICS TEXTILES PAPER OTHER TABLE I ASBESTOS DISTRIBUTION BY END USE AND TYPE , 1976 ^ *) (Short Tons) CHRYSOTILE 116,800 22,400 113,500 253,600 20,000 6,500 2,300 63,400 19,900 19,700 7,400 30,700 22,700 698,900 CROCIDOLITE 20,300 - 100 - 700 300 21,400 AMOSITE 2,900 200 - - 100 100 .1,200 4,500 ANTHOPHYLLITE 100 - - - -. 300 1,100 1,500 TOTAL ASBESTOS 140,000 22,700 113,500*---------253,600-*---------20,100 6,600* 2,300' 63,800*--------19,900*---------21,500*--------7,400 31,000 23,900 726,300 (*) Asbestos - 1977, R. A. Clifton, U.S. Department of the Interior, Bureau of Mines, 1977 TABLE II AIRBORNE ASBESTOS FIBER CONCENTRATIONS SANDING, DRY-MIXING AND SWEEPING^ UCC 018238 Operations Pole Sanding (1 to 1.5 m) Background (2.5 m), same room Background (7.5 m), adjacent room Hand Sanding (1 to 1.5) Background (2.5 m) same room Background (4.5 m), adjacent room Dry Mixing (1 to 1.5 m) Background (3 to 6 m), same room Background (5 to 10 m), adjacent room Number of Samples 10 3 2 11 2 2 2 3 2 Peak Fiber Concentration (Fibers Per Milliliter) Mean Ranqe 10.0 8.6 4.8 1.2 to 19.3 3.5 to 19.8 0.7 to 8.8 5.3 1.3 to 16.9 2.3 2.1 to 2.5 4.3 1.5 to 7.1 47.2 5.8 2.6 35.4 to 59.0 0.5 to 13;1 2.1 to 3.1 Sweeping Floor (3 to 15 m) 15 Minutes after sweeping 35 Minutes after sweeping 1 41.4 1 26.4 (*) A.N. Rohl, A.M. Unger, I.J. Selikoff and W.J. Nicholson, Science, Vol. 189, August 15, 1975, p. 52 UCC 018239 TABLE III AIRBORNE ASBESTOS FIBER CONCENTRATIONS DURING SANDING OF TAPE-JOINT COMPOUND v ' DATA FROM UNION CARBIDE CORPORATION Location Structure TJC Definition App. Tool Type Sanding Definition Tool Walls Ceiling Description Sample Definition Total Sample Time (Hrs.) No. Samples Airborne Asbestos Fiber Concentration (Fibers/cc >5u) Range Average New York City, NY High rise apt. building. Windows open, light breeze. 13, 14, 15th story. Humid ^750ft.2 of floor area per apt. Hand General Purpose, Ready-Mix Pole & Hand x x Finishing touch- 5 5 Personal up operation by 1 Area tapers. Scraping, sanding (generally light) & filling. 5 man crew, 1 man/room. 0.1-0.4 0.2 0.3 0.2 Ft. Lauderdale, FL Condominium apt. bldg. Windows in and gener ally closed. Little breeze. Ames General Purpose, Pole Ready-Mix X X Steady sanding by 1.5 7 Personal laborer. 10-15 7 Area minutes to complete 1 B.R. apt., /V500 ft.2 of floor area. 1.3-3.4 0.3-1.5 1.8 0.9 Hand X - Spot sanding bad 0.5 2 Personal areas. 0.8-1.1 1.0 Hialeah, FL Condominium apt. bldg. Windows in and gener ally tlosed. Little breeze. Ames General Purpose, Pole Ready-Mix X _ Steady sanding by 1 2 Personal laborer. 15-20 1 Area minutes to do a 3-5 room apt. 0.6-1.0 0.6 0.8 0.6 Dallas, TX Single level residen tial dwelling. ^2000 ft.2 floor area. Win dows in and closed. Ames General Purpose, Pole Ready-Mix X X Steady sanding by 1 4 Personal 0.6-1.8 2 laborers. 30 1 Area (after) 0.1 minutes to do com plete house. 1.1 0.1 Niagara Falls, NY Remodeled office. 12'xl0'xl2 * No ventilation. Hand General Purpose, Hand Ready-Mix X - One man, heavy 0.6 3 Personal sanding. 2.3-3.6 2.9 Detroit, MI Multilevel residential dwelling. ^3000 ft.* of floor area. No ventilation. Ames Topping Compound, Pole Dry Mix X X Steady sanding by 4 8 Personal laborer. ^4 hours 1 Area to complete. 0.6-1.3 0.5 ' 1.0 0.5 Minneapolis, MN Two-level residential dwelling. ~2300 ft. of floor area. Moderate ventilation. Ames Topping Compound, Pole Dry- Mix Asbestos Free X X Steady, heavy sand- 4 6 Personal ing. 1 man ^4 hours 3 Area 0.1-0.4 0.0-0.4 0.2 0.2 Denver, CO Two-story medical bldg. Two-story hall, many small rooms. Rain, no ventilation. Hand Ready-Mix to bury tape. Non asbestos ReadyMix Topping. Pole X X One man, moderate 3 3 Personal sanding. ~30 mins. 2 Area 0.1-0.4 0.2 0.2 0.2 (*) H. B. Rhodes, B. L. Ingalls. GDCT Dr^n Januarv/Fehruarv lQ7fi TABLE IV AIRBORNE ASBESTOS FIBER CONCENTRATIONS DURING SANDING OF TAPE-JOINT COMPOUNDS(* * Location Structure TJC Definition App. Tool Type DATA FROM OSHA COMPLIANCE INSPECTIONS 0) A - - Ready-mix F - -' H - -I - -- Sanding Definition Tool Walls Ceiling Description Sample Definition Total Sample Time (Hrs.) No. Samples Airborne Asbestos Fiber Concentration (Fibers/cc >5y) Range Average Pole Pole - X - X - Apparently 3 men sanding. - - - 0.5-2 0.7 - 1.2 8 Personal 4 Area 1 Personal 9 Personal 3 Personal 1.5-5.0 1.0-10.0 0.1 0.3-1.5 0.2-0.6 4.3 (**) 5.0 (*) 0.1 0.7 0.4 UCC 018240 DATA FROM EQUITABLE* ENVIRONMENTAL HEALTH, INC. CO One story annex to existing building. Non-asbestos for tape, fin ished with asbestoscontaining. Pole X Heavy sanding. 0.5 1 Personal 0.2 One man on 2 Area 0.1 stilts. 0.2 0.1 It - Non-asbestos Pole - X II 0.5 1 Personal 0.1 0.1 throughout. 1 Area 0.1 0.1 (6) (*) Supplied to Equitable Environmental Health, Inc. as part of a study of asbestos exposure In the construction Industry. Specific locations not Identified. Includes all particles L/D >3 L>5y . Estimated by TEM proceeding to be about 50-70% chrysotlle plus amphlbole. No split on relative amounts Is available. Location B C E G H TABLE V AIRBORNE FIBER CONCENTRATIONS FROM OSHA COMPLIANCE INSPECTIONS (*) DURING WET-OUT OF DRY PRODUCT AND CLEANUP AFTER SPRAYING OR SANDING Product Identification Operation Sample Time (Min.) All purpose TJC Spray Texture (**) Spray Texture (*.*) TJC TJC (Mortar) Wet-out H H ii ii 10 10 20 2 - Ceiling Concentration Fibers/cc >5u 5.4 4.4 4.9 4.0 2.7 D TJC TJC H TJC Sweeping ii n n Sweeping and Scraping ii n Sweeping 15 15 15 30 15 15 15 - 2.7 2.5 2.0 0.9 1.5 0.6 1.6 0.6 (*) (**) Supplied to Equitable Environmental Health, Inc. as part of a study of asbestos exposure in the construction industry. Specific locations not identified. Spray texture compounds are generally similar in composition to dry-mix tape-joint compounds with texturing material added. -26UCC 018241 TABLE VI SUMflARY OF AIRBORNE "FIBER" CONCENTRATIONS CONSUMER SPACKLING AND DRYWALL INSTALLATION UCC 018242 Sample NO. K-32 H-21 B-2S M-37 H-23 Date 6/21/77 6/21 6/21 6/21 6/21 Air Sample On Off Minutes 11:07A 7:16P <89 Blank 12:58P 9:10P 492 11:27A 7:27P 480 10:55A 7:20P 505 Description of Operation Outdoors- about 4' In air. See Figure 1 ). - Bedroom-^' off floor, 3 1/2' from side wall. 9' from end wall. See Figure 1 (a). Living room-x4* off floor, 3 1/2' from side wall. See Figure 1 (b). Recreation room - Center about 4* off floor. See Figure 1 (c). No. of Fields Counted 500 500 200 200 300 No. of Filter Section Used 2 Airborne Asbestos Concentration Mbers/lOO Fields Flber/cc >5u 3 0.005 2 0.8 1 7.75 -. 0.01 1 8.5 0.01 2 5.4 0.007 Comments PREPARATION AND INSTALLATION 16/22/77) H-24 6/22 9:00A 3:5EP 2:48P S:39P 429 H-30 H-28 6/22 6/22 H-27 6/22 K-16 *-18 6/22 6/22 3:38P 3:55P 17 9:18A :10P 2:42P 5:48P 422 8:57A 4:09P 2:41P 5:45P 440 9:10A 4: BOP 2:40P 5:40P 400 3:38P 4:30P 70 Personal sample. Operator preparing cracks for spackling. Removing old drywall. Cleanup after three opera tions. Installation of drywall. Spackling and taping with "wet" compound. (Taping In same area as TJC wet out.) Personal sample. Operator wetting out dry tape joint compound. Bedroom- 8* from side wall. See Figure 2 (a). During preparation, cleanup, and spackling. Living room - Same location as M-37. During various activities on other floors as noted. 100 200 100 100 Cellar- 4' from side wall. 12' from wall replaced. 4' from floor. See Figure 2 (b). During drywall removal. Cellar- Same location as M-36. During wet out of TJC and immediately following 100 200 1 141 1 8.5 1 18.5 1 17.0 1 17).5 1 7.0 0.2 Too heavily loaded to count accurately. Better than 1/6 of field obscured by particulate. Particulate In 5u range nay not be chrysotllc. 0.3 0.1 0.03 0.3 0.07 Loaded with small particulate fibers, short but within 5* range. Sore evidence of asbestos. TABLE VI (Continued) SUMMARY OF AIRSORNE "FIBER" CONCENTRATIONS CONSUMER SPACKLING AND DRYMALL INSTALLATION UCC 018243 Sample No. Pate . Air Sample On Off Minutes Description of Operation No. of Fields Counted SANDING OF SECOND COAT AND APPLICATION OF FINISH COAT (6/24/77) H-26 6/24 7:1QA 7:30A 20 Personal sample. Operator sanding spackling. Upstairs bedroom. Clean up after sanding. H-35 6/24 7:11A 7:31A 20 Bedroom - During sanding and cleanup. Same location as M-28. B-27 6/24 7:32A 3: OOP 448 Bedroom - After sanding and cleanup. Same location as M-28. . H-29 6/24 7:1QA 2:54P 464 Living room - During and after sanding and cleanup of spackling and application of finish coat. >-79 6/24 7:37A 8:50A 73 Personal sample. During sanding of drywall In cellar. Cleanup after sanding. Application of finish coat. 8-22 6/24 7:37A 7:52A IS Cellar - during sanding and cleanup. Same location as M-36. H-34 6/24 7:54A 2:55P 421 Cellar - after sanding and cleanup. Same location as M-36. 200 200 100 100 100 300 200 No. of Filter Section Used 1 1 1 1 1 1 1 Airborne Asbestos Concentratinn Fibers/100 Fields Fiber/cc >5u Comments 5.75 8.0 47.5 12.5 10.0 4.1 . 8.75 0.2 0.3 0.07 0.02 Geometric chunky eaterlal present. Also rod-staped with light refractive Index. 0.1 t 0.2 0.01s % i FINAL SANDING ANO CLEANUP (6/25/77) N- 66 6/25 12:43? 12:57? 14 Personal sample. Operator sanding spackling. Upstairs bedroom. Cleanup after sanding. >-60 6/25 12:42P 12:58? 16 Bedroom - during sanding and cleanup. Same location as M-28. K-68 >-64 6/25 6/25 12:59? 8:00? 421 12:15? 8:00? 465 Bedroom - after sanding and cleanup. Same location as M-28. Living room - During and after second sanding and cleanup. >-72 6/25 1:03? 1:36? 33 Personal sample. Operator sanding TJC in cellar. Cleanup after sanding. Ifc65 8-12 6/25 6/25 1:03? 1:37? 34 1-.45P 7:11? 326 Cellar - During sanding and cleanup. Same location as M-36. Cellar - After sanding and cleanup. Same location as M-36. M-22 6/25 >-81 - 1:55P 2:05P 10 Blank Personal sample. Handling of work clothes after sanding. Other clothes sorted and added to washing machine during most of period. (Operator #2) - >-97 7/9 8 7/10 10:30A U:00A 7:25? 7:20? 1025 Outdoor sample. Sama location as M-32. 500 500 300 300 500 300 500 200 500 500 2 2 2 2 2 1 2 1 2 *2 1.9 1.0 5.2 5.3 1.7 3.6 1.6 6.75 0.8 1.0 0.09 0.04 0.008 0.007 0.04 0.08 0.003 0.5 * TABLE VII SUMMARY OF AIRBORNE FIBER CONCENTRATIONS FULL ROOM CONSUMER DRYWALL INSTALLATION COMPLETION OF STUDDING - HANGING ORYWALL - START OF TAPING (8/3/77) Sample No. N-73 Datfe 8/3/77 N-52 8/3 8-3 8/3 J-2 8/3 __________ Air Sample On OH Minutes 8:30A 6:30P 600 8:20A 6:27P 607 7:43P 7:46P 9:1 OP 9:1 OP 87 84 Description of Operation Area-Before handling compound. Located in living room 1st floor ~6' above floor on mantel of fireplace. Area-Before handling of asbestos. Located in construction area ^6' above floor on north wall ** center of room. Personal (Operator #1) Taping joints with ready mix. Personal (Operator #2) Taping joints with ready mix. No. of No. of Filter Airborne Asbestos Concentration Fields Counted Sections Used Fibers/100 Fields Fiber/cc 5U 500 5 3.0 0.004 100 1 63.5 100 1 36.0 100 1 17.0 0.08 0.3 0.1 UCC 018244 COMPLETION OF INSTALLATION AND COVERING OF TAPE (8/4/77) N-53 8/4 9:36A 1:48P 252 Personal (Operator #2) Taping joints with ready mix. N-70 8/4 9:35A 1:48P 253 Area - During taping. Located ~ 6' above floor area near center of north cellar wall. APPLICATION OF SECOND COAT OF COMPOUND (8/5/77) No air samples taken 200 200 2 7.25. 0.02 1 5.5 0.02 -- ............ ......... ...-- TABLE VII (Continued) SUMMARY OF AIRBORNE FIBER CONCENTRATIONS FULL ROOM CONSUMER DRYUALL INSTALLATION UCC 018245 Sample Air Sampl e No. Datfe On Off Minutes Description of Operation FIRST SANDING CLEANUP AND APPLICATION OF FINISH COAT OF COMPOUND (8/6/77) No. of No. of Filter Fields Counted Sections Used N-76 8/6 10:00A 10:44A 44 Personal (Operator #2). Hand sanding. 100 Tape joint compound. 1 N-89 8/6 11:00A 11:23A 28 Personal (Operator #2). Hand sanding. Tape joint compound 100 1 B-14 8/6 11:58A 12:1 OP . 12 Personal (Operator #2). Sweep up after 100 first sanding. 1 N-94 8/8 10:01A 10:47A 46 Personal (Operator #3). Hand sanding. Tape joint compound. 100 1 8-18 8/6 '0:55A 11:29A 34 Personal (Operator #3). Hand sanding. i Tape joint compound. OJ ? N-75 8/6 11:57A 12:11A 14 Personal (Operator #3). Sweeping up after first sanding. 100 # 100 1 1 N-71 8/6 9:59A 11:23P 84 Area. During first sanding of tape 100 joint compound. Located ^6' above floor near center of north wall (cellar). 1 B-30 8/6 11:57A 12:12P 15 Area - During sweep up after first sanding 100 Located ~6` above floor near center of north wall cellar. 1 8-31 8/6 12:39P 4:46P 237 Area. After sanding and sweep up. During 100 final application of tape joint. Located near center of north wall (cellar). 1 B-10 8/6 12:23P 4:39P 256 Area. After sanding and sweep up. During 300 final application of tape joint compound. Located first floor upstairs. Living room on mantle of fireplace. 3 Airborne Asbestos Concentratlo Fibers/mn p-iolw* criVguc__r//c__c . 60.0 22.5 0.9 0.5 22.0 45.5 40.0 15.0 25.5 1.3 0.7 8.8 0.7 0.2 14.5 0.7 11.0 0.03 10.5 0.01 SECOND SANDING AND CLEANUP (8/10/77) TABLE VII (Continued) SUMMARY OF AIRBORNE FIBER CONCENTRATIONS FULL ROOM CONSUMER DRYHALL INSTALLATION UCC 018246 Sample No. 8-17 N-66 P-60 U-4 N-7 B-8 8-20 P-65 N-8 N-10 i CO A-75 N-85 N-55 A-74 N-6 A-77 A-71 Date 8/10/77 8/10 8/10 8/10 8/10 8/10 8/10 8/10 8/10 8/10 Air Sample On Of 9:27A 10; 01A 10:02A 10:28A 10:29A 10:46A 10:48A 11:09A 11:18A 11:43A 9:25A 10:00A 10:01A 10.-30A 10:31A 11:12A 11:13A 11:43A 11:52A 12:13P Minutes 34 26 17 21 25 35 29 41 30 21 8/10 12:47P 4:33P 226 8/10 8/10 9:24A 12:18P 174 9:27A ' 10:15A 48 8/10 10:17A 11:44A 87 8/10 11-.52A 12:14P 22 8/10 12:19P 5:58P 339 8/10 12:17P 5:59P 342 Description of Operation No. of No. of Filter Airborne Asbestos Concentration Fields Counted Sections Used Fibers/100 Field* Fihor/<-r . s. Personal - Operator #2. Sanding TJC Personal - Operator #2. Sanding 100 . 100 1 1 24.5 13.5 0.5 0.4 Personal - Operator #2. Sanding (ceiling). 100 1 24.0 0.9 Personal - Operator #2. Sanding (ceiling). 100 1 20.5 0.7 Personal - Operator #2. Sariding (ceiling). 100 1 22.5 0.6 Personal - Operator #3. Sanding Personal - Operator #3. Sanding Personal - Operator #3. Sanding Personal - Operator #3. Sanding Personal - Operator #3. During sweep up and vacuuming after sanding. 200 200 100 100 100 . 1 1 1 1 1 8.0 9.35 20.0 23.0 36.0 0.2 0.2 0.3 0.5 1.2 Personal - Operator #3. After final sanding and cleanup. Performing normal household duties including laundering of work clothes used during taping and sanding. 100 1 17.0 0.05 Area. During second sanding and cleanup. Located first floor living room ^6` above floor on mantle of fireplace. Area. During second sanding of TJC. Located ~6' above floor near center of north wall cellar. Area. During second sanding of TJC. Located ^6' above floor near center of north wall cellar. Area. During sweep up and vacuuming after sanding. Located ^6* above floor on north wall. Area. After final sanding and cleanup. Located first floor living room ~6` above floor on mantel of fireplace. 300 200 100 100 100 3 2 1 1 1 11.0 10.25 31.0 15.5 10.5 0.02 0.1 0.2 0.5 0.02 Area. After final sanding and cleanup. Located ~ 6' above floor in north wall r ml 1 ar 100 1 18.0 0.04 TABLE VII (Continued) SUMMARY OF AIRBORNE FIBER CONCENTRATIONS FULL ROOM CONSUMER DRYWALL INSTALLATION UCC 018247 Sample Ko. Oatfe __________ Air Sample On Off Minutes Description of Operation No. of j No. of Filter fields Counted Sections Used Airborne Asbestos Concentrat-in Fibers/1 uu Ffelds ' Fi befy^ RESIDUAL EXPOSURE AFTER COMPLETION OF INSTALLATION (8/11/77) A-72 A-76 Z-4 i CJ ro 1A-70 P-56 8/11/77 8:53A 9:10A 17 8/11 9:12A 5: OOP 468 8/11 9:13A 5: OOP 467 8/11 8:45P 5:01P 496 8/11 8:42P 5:01P 499 Personal (Operator #3). Vacuuming first floor living room, kitchen and den after final sanding and cleanup. Area. Day following completion of ' work in basement. Located in kitchen area **6' above floor. Area. Day following completion of work in basement. Located on mantle of fire place ^6' above floor. Area. Day following completion of work In basement. Located in stairway of cellar *7' above cellar floor. Area. Day following completion of work in basement. Located on north wall of cellar ^6' above floor. 500 500 500 500 500 4 * 0.1 3 ' 0.8 4 3.7 3 1.0 4 2.6 0.004 0.001 0.006 0.001 0.004 TABLE VIII AIRBORNE ASBESTOS FIBER CONCENTRATIONS SPRAYING OF FIBRATED ROOF COATINGSr*) DATE 9/25/74 BINDER Cutback Asphalt APPROXIMATE WT. % ASBESTOS 7.7 AIRBORNE ASBESTOS CONCENTRATION (FIBERS/CC >5u) 0.003 0.006 10/9/74 Cutback Asphalt 7.7 0.072 0.027 12/10/74 Asphalt Emulsion 2.8 0.01 0.02 5/19/76 Asphalt Emulsion 2.8 0.3 (*) Data from response by the Flintkote Company to "Changes in the National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) (7) -33UCC 018248 TABLE IX AIRBORNE ASBESTOS FIBER CONCENTRATIONS * TEAR-OFF AND APPLICATION OF BUILTUP ROOFING ^ Date 3/14/74 4/10/74 5/21/74 7/25/74 11/20/74 12/16/75 8/16/76 8/16/76 Location Wisconsin Indiana Pennsylvania Indiana Colorado Colorado Indiana Indiana Operation New Application Tear-off Tear-off and Replace Tear-off and Replace New Application New Application Tear-off and Replace New Application o i d Airborne Asbestos Concentration (Fibers/cc >5y) 0.2 - 0.6 0.0 - 0.2 0.1 - 0.3 0.1 - 0.2 <0.1 . 0.0 . 0.0 (*) Data from response by the Johns-Manville Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) ^ *. -34UCC 018249 AIRBORNE ASBESTOS FIBER CONCENTRATIONS SPRAYING UF HIGH-PEkFORMANCE INDUSTRIAL AND TRADE COATINGS O perator spraying ship 41 0.4 h u ll in drydock. toCo.in3J - A ni to 4- c o to o u 4-> *O to xv>. r-. tJQa-J *tsorMO-- s. o3 CL o ai o 4(-0> T!3- Osaa-i 4oOu->i -ratro- ccn -X f- o >,0-0 to -a .i Tca3t o CL J_ to E O >*- 3 i_ 4-> O to O IO H_ i- "O O <0 3 vit- a cn o C -X <+r- (_> >4- >> o <a <0 T3 U L. to a. >> to Uo TOJ J- X O 4- -r4J Ol io sC0-1L--ar0-i E0i_ o to 4- cnto cr- > t0-1 >(O>=M (U UE CL 4- IO to O T~ ai 4J -a ocl c<- <co oo CO CVI ItDo >co 4-> rO CM c s U 4- <0 r 4-> O to U L. to o O (U 4-> -*-> c <D rtJ =3 T- l torn <y o C a. o to ro o *-* E E ro ai u C7> < c r- C c*n O.H-1 c f to s- co io *-- a 4-> Oi to to u u *o s, a> .1 CL +J 1 1/1 *41 co 1 ^^ c r~ 1 to . |3 . 4J O | 3Xi O IO 11 . <-- w | r-- 01 . O iI Q to Io X 4- O 0) Vi to L- 4- CL) CL tO X3 CL E 4-> to <C - 3 C C r-- O fO -f-- r-- 4-1 O tO UO Cl T- Isi oc I QE. ICO itno oi -r- to t/) I -o S_ C cr- (*O t0O to t-- VI c S' o E 'r~ j0;1 t0o1 t0o1 CL O j- I- CO CO 8 a. _ 4J i--- cn -o o 3U L- C 011 4-1 4- r" 4-1 to IO oO cn o 4CJ- *uar-i Otoo 4c*-" cin uto ai (01.t3-oc -uOtu- =We5oJr ou in o * -35- UCC 018250 CfMIj TABLE X (Continued) AIRBORNE ASBESTOS FIBER CONCENTRATIONS SPRAYING OF HIGH-PERFORMANCE INDUSTRIAL AND TRADE COATINGS (*) Based on to ta l formulation as sprayed. C om T- A 01 V) P cU 4o- l. oO O M4J JCO .0O) Cfll *" Ifl U 0) O f<< Cij u u. 0t r-- a) V*CEO0lH*E" SC* c o r-- M (O SQt a O oo toO CoO too oo <ot o o ot u> CO to to CM CM r> cn s. co r-- > *re at L. +* a. x ia at lm |c I >> H> 1-- 1 L. r-- CL <0 I tA X cn c C>3t to i-- S- xcl re A L. cn 55 1 S- u s L. t- oc oo oo M !- CO T3 L r-- I 4J *r- fO U. 1 i~ at +J f- re *i- at 0> *i- r- at x> at +> Q. 3 <0 OjQ 3 Jr CL c O -r- i CL X o at c 3 CD a1 a. to --I (OA X 4- O UU i/I s- +-> at cl re xt CL E +- </l < *r- 3: t 3c c 3cn cn (/> to at u t. <r* to to u IA at o $- ~a 2 3 O CM oo oo oo at cn c c re f- CL >0 re r-- S_ r-- Cl re A X i- r-- o re +- o re >i- +-> at t. cl at o> 3 T> at i. o Q. CL c cn 1c r- re 1 >t re o 1 S- CL C 1 l/l 04* o 1 S. TJ O O i- ii -m re re x at i i~ c cn at x Ji cl o re o -a r-- i i. < co CO CM Oo o to o o |sC cn cn t. cco co: at " r-- 4-t CL nt E<0 CCT 00 <IA at co 3 3 non. c c o. +J T3 L c*- --*- 4aJt flj 3 C CL jO c" : cn cn l. c co 3- o o o (X re cl 3: cn Su a. % VO o a: fs. I r>i. oi o r> 5 -36- UCC 018251 CO CO re- 3I AIRBORNE ASBESTOS FIBER COUNTS SPRAYING OF LAMINATING RESIN(*) Based on to ta l formulation as sprayed. C o in r* A OS l/> *- c o m cs OL. jq 4Wa-> UcJC'in/Si s- x> as l. r- W U HI << CJQ O *r- O U. LO o oo o ro O as ^ ra-- Eas c IPS <n *--1 S' CVI I >> fO T5S i- C -r" s_ 0 WT3 OS +-> ata> Cl ro i-cl w O 0i-1 oioa. finl oCL TC- o-C ro--> >. *0 S i- c Qj cml <0 J-rO- c 4- 4LO-> *mQr-J "<OD ns L. Cl tn i~ a.in a> cn o ns ac 1O'r U Ol in ro in LO in ro >r1a>-->> 1/1 L. C in cl o ns in 1-- 1 c cn u M- v o in as 4- as n <0 L *r- sas- o>vsoa. tc- zo ~a os +j c. c3 0 Cl co Q. $- 3 as >rt31 in Cl 1 CL S- V. 0 tcol| t- JZ U in iO X OS 4-> Oi-o -*-> <uW q. e +-* -o ac-r- 3: <(A in o 'c as - in in 0 as Cl i- 3 L. O. V. as as TO 1-- +-> cf- <0 in S- as co as >, C r-- as 0 CO CL CM CM "aOs +j 1 s_ ;0 Q-. i| 3 as . m cl 1 Q. 1 1-- xO: ns in t- as g as o cs ea rn i**. GO O as I-- o <0 <" r- 4-> CS <0 i- u OS *-- Eo 'Sai O ctooo as u 3 u <0 43 C o z; <oe CO c 1 toO 00 01 4J r-- IO g-g* /> (A 2 CvToi ro r-- Jl 00 CM I O ro 1 z ro1 z -37UCC 018252 O CM II table XII AIRBORNE ASBESTOS FIBER COUNTSGRINDING AND SANDING OF RESIN-BASED SYSTEMS CONTAINING ASBESTOS Sample Designation Commercial Apollcatlon A. THERMOSET RESIM (Polyester! 1929-82-3 1929-82-4 1929-82-5 Fabrication, of reinforced fiberglass pipe. Date 2/27/73 ft Asbestos Approx. Type Wt. t Operation Sample Time (Min.) RG-144 2-3 a . 2-3 a 2-3 Operator pulls pipe along line. Saws off end with circular saw. Same operation as 1929-82-3. Operator removing end of pipe with scarfing machine. 19 49 45 Airborne Asbe: Concentrate (Fibers/cc > 0.1 0.1 0.04 1-13 1-6 m 1-26 6-8 1-39 Fabrication of FRP tanks and pipe. 1929-84-4 1929-84-5 Production of artificial bricks. N-20 N-25 Production of fiber glass boats. . B. VINYL LATEX RESIN J-33 R-43 0-35 Sanding of vinyl latex paint. 0-4 8/13/74 RG-244 1.4 ft . a 1.4 Operator shaping end of pipe with bell & spigot ' machine. Operator cutting off pipe end and light grinding on exterior surface. 8/13/74 m a% RG-244 1.5 , Operator grinding inside of 13' I.D. x 26* tank. a 1.5 a 1.5 Continuation of same opera tion as 1-26. Operator grinding edges of miscellaneous small parts. 3/8/73 a RG-244 a 2.0 2.0 Operator cutting with sabre saw. Operator trimming with sabre saw. 11/26/74 RG-244 0.5 a a 0.5 Operator grinding Inside of boat hull. Operator grinding. 16 17 16 5 25 44 39 11 4 0.3 0.2 0.4 0.3 0.3 0.1 0.2 0.0 0.0 3/8/77 a a T-135 a a a 1.1 1.1 1.1 1.1 . Operator hand sanding overhead panel. Operator hand sanding wall panel. ft 12 . 11 16 16 0.3 0.06 0.1 * 0.0 -38UCC 018253