Document rxMV9NOenbM7n5q6onQOm3pwV

Memorandum To: Brian Clary From: Steven Johnson Date: 15 June 1995 Re: Bird I have completed the research on asbestos standards, NESHAP standards and asbestos phase out dates. Asbestos Standards Initial standard from December 1971 -- *5 fibers per milliliter average over 8 hours *Above 5, less than 10 fibers per milliliter for a total of 15 minutes permissible. July 1972 to July 1976 - *5 fibers per cm3 average over 8 hours *At no time to exceed 10 fibers per cm3 July 1976 to July 1986 -- *2 fibers per cm3 average over 8 hours *At no time to exceed 10 fibers per cm3 July 1986 to September 1988 -- *0.2 fibers per cm3 average over 8 hours September 1988 to August 1994 - *0.2 fibers per cm3 average over 8 hours * 1 fiber per cm3 average over 30 minutes August 1994 to present *0.1 fiber per cm3 average over 8 hours * 1 fiber per cm3 average over 30 minutes I have attached the relevant Code of Federal Regulations and Federal Register pages. NESHAP Standards I have attached the NESHAP standards -for removal of asbestos. The difference between the 1994 and the 199T versions is the addition of Appendix A to Subpart M in 1994. There are several differences between the 1984 and 1991 versions in form, but from what I can tell, the substance does not appear to be significantly different. BIRD 012272 Phase Out Dates In 1989, there were three dates set for phasing out the manufacture, importation and processing ofasbestos containing products. They were, August 27,1990; August 25,1993 and August 26,1996. In 1994, the EPA changed this scheme so there are only two dates set, August 27, 1990 and August 26,1996. ( 763.165 and 763.167). Plus, the products affected are changed somewhat. The 1994 rule has only flooring felt and new uses of asbestos phased out as of August 27,1990. ( 763.165(a) and 763.167(a)). Set for the August 26,1996 phase out are: commercial paper, corrugated paper, rollboard and specialty paper. ( 763.165(b) and 763.167(b)). Several asbestos containing products are conspicuously absent from the 1994 rules. Products now subject to the August 27,1990 phase out are not to be distributed after August 25,1992. ( 763.169(a)). Products now subject to the August 26,1996 phase out are not to be distributed after August 25,1997. ( 763.169(b)). This differs from the 1989 rules which had three dates set for the distribution phase out. There were also three dates set for the implementation of labeling requirements in 1989. This has also changed. Now, products subject to tire August 27,1990 phase out are to be labeled beginning on August 27,1990. ( 763.171(a)). Products subject to the August 26,1996 phase out are to be labeled beginning on August 25,1995. ( 763.171 (a)). I have attached the rules for your reference. Ifyou have any questions, let me know. BIRD 012273