Document rY0rZwrX6YvB1aqy2ppx0z9V

Dr r. r \.'r'c'>- MD Jcl.ii-i-IMnvi:: : Corpointioii Groom vod Plcra Denver Color..do OnflT hoar Di Fright, r_lj 1:1 re ,-unl 11|>- r'-n l.irrt You will have received n cony of the prepared letter to Di rihoiT- v-hiili t.tevo holmes and 1 liavo arnltod, but novel < hole: n Profl in herewith onclvaoJ. I ai.< n.'-o cue la .In,, herewith pilot ovopi or: o ilia;: vonie'i i nc:it to Dr Solikoff which vero ucod in cci.ipi line Mg'.res and 3 in ny paper. Mr Solon liaa given mo a cop;' of your memo dated Crbr! Juno 1073 f nd I hope that too draft letter liao adeonatoly dealt viih most eJ` your quoric:.. X will, however, briefly reply to each nur.-tion In turn In caoo thoro aro points which remain nclc.tr to yon. Pnro 2. Table a, 1) Tlic critoria for a dinfjiosio of asbootoe have, to tho bi oi. of my knowlodgo, changed since 1930. In 1930 radiological r.puc.--\ r.cce. symptoms and cigna wore used and tulierculosia oft.on conm.-.tin. lacuc. (Coolto's caoe in'1924 rat an cir.i.iplo of this). r>. J95V radiological tochnlquo had probably ior.provod but the crit. i.i far diagnosis had not greatly altered. It van in tho early 19 o-j <)io tho Pnoumocondcio Modienl Pni.s'c b..gnu tv in:m upon a re< e-ed D in adi'.tion to other criteria (HcViltio, lQf^O'h Ac you l:r , tho UICC/Cincinntti clnooiflcation hao further added dingno: ic /aluo to X-raye. 2) The caso diagnooed in 1957 would havo boon based prodouin;u. t - or. basal raloo und oxposuro hiotory and that in 19(i3 on ralor. > r; > DCO ana oxposuro hiotory. 3) Tho answer to thio quootion is that both thoco caooo would hr c b exposed for much of thoir employment to dust concentration:-. : cove 2 fibros/cc. Page 2, Solllcoff 'j Crnnh 1) This is answered in (0) on page j of tho attacliad letter. 2) Fibrosis was not counted cioro than onco in any ono portion nc wan dono for pleural thlclconlng. Pare 1. Solllioff's Graph 3) This is difficult to answer directly but bocauoe I uttompted io u/ the UICC/Cincinntti elasolflcatlon and John Knox did not, thrre ttuot havo been basic dlfforoncoa in interpretation. John l.nox dli not record X~roy chanfio* a* botnc sic*'1 fiennt unlcsn they v vo compatible with t)io entiro clinical picture* Thin is expin im:c In ltom (6) of tho draft lottcr* Coni f <1 2 Jj ) Abnormal no explained to Dr FolJkoff, ru-nU a *. 1 r*..-!. o ' ;' W .i I m t < jj* i . 11 i lie: of no to ouch a n ca* ii i.c. nil. . pleural tlilrUniln;; nr. a rt.-iilt of pant illncMier., TD, otn, etc. < i *i 5) I <!<> hm o A*rny/i, of Q non-rvprnucJ population nnl an cu*. r-n X-rayln/r voluntorrii from officer* to nupplrtm-nt thir.* Th- t of matching usbor.tou vnrl^rc v.'ith thic (jroup nn b* dime 1m no nttor.mt ban yot lirnj r.rdn to compare X-rnyn in Iho tv<> i Tint Q~f.) yrnrn ^rom> obvlouoly includes non 1ml i vJ dua 1 r. In oxpofted calrrory X-rnyod cc ju'W ntarler*, In iin* ^roup ni. X*rayc increase with n^o. 6) I lmvo X-ray data for non and vooion. Paco a, (l) nn'l (2) iDcoc questions uro answered in tho draft lottor* i I hope thcao points nro not; clear to you. With best wishes. Yours sincerely, hjltok lbv.tnsow; AabootooiB in Croat Britain, J C McVittlc, p.128, Annals of the New York Acadcny of Fcicnccn, Vol, 132 Art.l. malnrtcr'l Effects 1! CL/PS cc: FJS/MS DK11 VTII SJI Dr 0 V Wight >ro Johns-Haiivl lie Corporation Croanwood l'laza Donvar Colorado 80217 Tuesday 3rd July 1973 Door Dr Vright, Solil:orf nnd the You wi s/hicli . horowl! tablcB and 3 1 ho pruj>o..i.u letter to Dr foliboff ted, but never! holcsn Draft 4 it s:-ing liorcwith photocopier, ol' tlia voro uced in compiling figures 2 Mr Soloi I hope 1 queries, in caoo > memo dated 22n<1 Juno 1973 end eonatoly dealt with most of you: only to oach question in turn n unclear to you. Pare 2 1) Tho criteria for a dio-gnoals of asbestos have, to tlio best of ny knovlodgo, changed since 1930 In 1930 radiological nppcarr.ncci;, symptoms and nlgno wore used and tuberculosis oft.on confused tho ioouo. (CooUo's cooo in 1924 vat an o;:arr.plo of this). Jn 1957 radiological tochniquo had nroMViiy ir.r.rsvod but the criteria for ainipioai: had not groatly altered. It vas in tho early 19f0o that tho 1`noumoconOolo Modlcal Panolo bocan to insist upon a rcd. cod DC in addition to other criteria (McVittio, 1964)*. Ac you lnx.w, tho UICC/Cincinatti clasoifleation hao further added diagnooic value to X-raya. 2) Tho caso diagnosed in 1957 would have boon based predominant! ' on basal raleu and oxposuro history and that in 1968 on rales, X-rnyc DCO ana exposure history. 3) The ariewor to this question Is that both theso cases would has 0 be xpoeod for much of tlioir employment to dust concentrations abovo 2 fibros/co. Pago 2, Sollleoff' Graph 1) This is answorod in (8) on page 3 of tho attuchod latter. 2) Fibrosis was not counted more than ones in any ono person no wan dona for pleural thloUoning. Pare 3. Sollhoff's Oraph 3) This Is difficult to ansvor directly but boeaueo I attempted to ui the UICC/CIncinntti classification and Joins Knox did not, there must havo been bnsic difforoncoo in lsitorprctntlon. John Km>\ <li< not record X-rny changon as bolsig c! gnl fi cant unlo.ts they wore compatible with tlio ontiro clinical picture. Till e is oxplalind In item (6) of tho draft lotter. Coni ' (I -2 4) Abnormal X-rays, ns rvplalnod to Dr Bollkoff, moant all rndloloclcnl abnormal!tios of noto such no eurdluc enlargement, pleural thlrkrnlnc ae a result or past l'inosoos, hoalod lnaetlv TD, ote, otc. 5) I do havo X-rnyo, of a non-oxpnood population and an currently X-ruyinc volimtooro from offlcrn to supplement thin. The task of mutch In/; aoboetos workers with this croup can bo dono but no attempt hue yot boon outdo to compare X-rayo in tho two popula The 0-9 yen. olviouoly locl-t'cs ui.te I.hJ! vt.lral In the a oxposo'd entocory X-rayod ao now startorr.. In tlio croup abnormal X-rayr increase with aco. 6) I huvo X-ray data for non and womon. Pnro *1. (ll nn<1 (O') Thoso questions are ansvored in the draft lottor. I hopo tlieeo points aro now clear to you. Vith best wishes. Youro sincerely, HILTON LCVINSOIIN 'Aaltostooit in uroat Britain, J C HcVittio, p.128, Annnla of the New York Academy of Scloncoe, Vol.132, Art.'., Btolocical Effecto of Aabootoa, 19&5 hcl/ps cc: FJS/MS DW11 WPH SH Senior Staff Proat Paul Kotin, H.D CopiaaiPile Rat PROPOSED CHANGE TO ASBESTOS STANDARD Today (October 9, 1975) the Occuoational Safety and Health Administration (OSHA) will pijhlir" ir. the Federal Register proposed changes to the job health standards on'isoestos. These proposed revisions will include: -- reduction of permissible exposures to an 8-hour time-weighted average of 0.5 t/cc; -- reduction of ceiling limit (determined during any 15-minute samollng period) to 5 f/cc; --establishment of additional reoulrements for regulated areas, employee rosters, hygiene facilities, worker training and information programs, signs and labels, and monitoring and medical surveillance programs; --extension of the period for retaining monitoring and medical records to 43'years, or for the duration of the employee's emloyment plus 20 years, whichever is longer (current retention period is three years for monitoring and 20 years for medlcai records); --exclusion of construction activities from the revlaud standard, continuing coverage of that Industry under the existing standard. By far the most important change is the orooosed reduction of the permissible 8-hour time-weighted average exposure to asbestos to a.5 f/cc from the 2 f/cc standard which was to take effect July 1, 1976. we are concerned by the proposal for several reasons. First, by tne haste with which the standard was proposed and the apparent lack-of consultation with either Industry or labor, or even other appropriate offices within OSHA. Comprehensive inquiries have failed to identify the ourca of the pressure on OSHA to reduce the standard from 2 f/cc, as planned for July 1, 1976, to a.S f.cc. Second, customary procedures have not been followed in the development and publication of this proposal. For example, preparation cf an economic impact statement usually preceles publication of a proposed standard; however, this procedure has been reversed in this situation. Third, while the proposed revision Includes a bib! lgr;>hy of approximately SB references, none ot these referee** contains data that were not known at the tlee the 2 f/cc standard was established. At the recent International Congress on Occupational Health at unqhton, England, however. Sir Richard Doll reported on the mortality esperience for lung cancer in employees of Turner Brothers through 1*74. and he Indicated a iun? _uncer rate three times over that expected In asoestos workers. At tiie same meeting, Or. Muriel Newhouse, In collaboration with her Statistician Dr. Ceoffrey Berry, reported on the development of a prospective mathematical, model from whlcn they concluded that the attack rate for mesothelioma in the work copulation of Cape Aabestos, United Kingdom, would be approximately 11 percent. This figure Is significantly higher than tne 7 percent rate pro}ected by Dr. Irving Sellxotl tor his highly exposed asbestos insulation workers, and the more generally accepted rate of 4 percent in asbestos occupational qroups as a whole. These findings, though, do not provide support for the proposed reduction of the standard. The assumotion made by Doll that the Turner population was exposed only to 2 f/cc is not supportable by fact. The Newhouse data uses a mathematical model that has serious liultalions in tne opinion of other recognized statisticians. Johns-Manvllle adheres to the position that 2 f/cc, the standard promulgated for Implementation July 1, 1*7*, is a level of exposure at which there Is no haxard as measured by impact on morbidity and mortality patterns. In addition, the )ustlflcation for, as well as the feasibility of, many other aspects of the proposed change are open to serious question. In accordance with regulations, Johr.s-Hanville will respond to the proposal in the Federal Register within ffl days, following which a public hearing will certainly be held, although it may be postponed until soring since an Inflationary impact statement must be published at least'JR days prior to any scheduled hearing. While we ere preparing oiir response, it is the recommendation of Health, Safety end Environment thet J-M'e position regarding the proposal be that the review and analysis of all scientifc data available do not support the proposed reduction of tne permissible exposure to asbestos from 2 f/cc to 8.S f/cc.