Document rxdy0KEz8E0ewGkvgmYzooy6v

FILE NAME Manville JMA DATE 1978-1980 DOC JMA334 DOCUMENT DESCRIPTION Resilient Floor Covering Institute Reports RE Asbestos & Government Regulations with Relevant Correspondence es The Government Research Corporation 1730 M Street Washington DC 20036 Telephone 202 857-1400 TWX 740 322-0166 GRC WSH CURRENT GOVERNMENT ACTIVITIES AFFECTING THE RESILIENT FLOOR COVERING INDUSTRY For Presentation at the Committee Meetings . Resilient Floor Covering Institute Monterey California August 14-15 1980 Faye White Product Safety Analyst PublisherPublisher National Journal PRODUCED TABLE OF CONTENTS . ' ' ' ' ' @' ' ' ' &fi ' &' @ 8 8 ' ' @' ' ' ' @' ' ' ' ' ' 8 oe ' ' ' ' ' ' ' ' ' ' ' ' ' @ ' PRODUCED RFCI Report August 1980 ASBESTOS Asbestos Substitutes Conference The Environmental Protection Agency and the Consumer Product Safety Commission under the aupices of the Interagency Regulatory Liaison Group IRLG sponsored a three conference July 14-16 on the technical and health aspects of asbestos substitutes The purpose of the workshop was to provide the health and safety agencies with some of the information needed for making regulatory decisions about limiting the use of asbestos The agencies are anxious to gather information relating to the availability and costs of substitutes and plan to consider these data in regulating asbestos Both EPA and CPSC view the conference as a success Although costly and consuming to arrange the meeting provided the two agencies with much useful information and the opportunity to meet with representatives of many industries on an informal basis according to staff members Those attending the conference are also likely to have benefited from some portions of the exchange as there seemed to be something for everyone Users of asbestos and containing products were briefed by industry representatives on the advantages and availability of newly developed asbestos substitutes and replacement products Manufacturers were provided room to display and hand out promotional materials about these products Also the scientists did not hesitate to challenge the primarily preliminary findings presented by their peers on the health effects of asbestos substitutes With alacrity they debated the appropriateness of the scientific method and nomenclature used in the studies The agency staff members may have gotten more out of the conference than was anticipated by industry representatives One staff member told GRC that it's now clear that substitutes exist for every use of asbestos This staff member made no distinction between the performance and cost of the substitutes and asbestos despite the fact that this point was emphasized by those still dependent on asbestos for their products Industry representatives said that more time is needed to develop adequate substitutes at a reasonable cost If alternatives were economically and technologically available industry would have already eliminated the use of asbestos in most products according to one speaker PRODUCED JM - 73 At this point the government appears likely to force the switch to alternatives by limiting asbestos use through regulation Both EPA and CPSC announced in October 1979 advance notices of proposed rulemaking that they will consider the costs performance and health effects of asbestos substitutes before regulating Despite the announcement it has become clear that these considerations are likely to have little impact on regulatory action One reason is that neither agency is bound by economic factors in selecting regulatory options so long as it shows that the rule is reasonably necessary to prevent unreasonable risk to health Secondly The potential health hazards of the substitutes are unknown because most of the information available is inconclusive Finally staff members still claim that little economic data has been made available to them The conference was not successful in because industry clams up when it comes to eliciting giving us this type economic of information data a staff member contended Without it we will have to make guesstimates he added Most likely the guesstimates will support the agency's objective In all the conference appears to have been of use albeit limited to EPA and CPSC The agencies did get the information they were seeking on the development and availability of asbestos substitutes It is likely they will use this information in setting new regulatory priorities after the rulemaking proceedings on asbestos are completed On the negative side the agencies were not able to fill the gaps in their knowledge on the economic and health effects of substitutes Although this lack of data will not stop EPA and CPSC from eventually limiting asbestos use it will definitely prolong the regulatory process providing industry with time to eliminate asbestos use voluntarily in some cases PRODUCED JM - 83 OSHA The recent U.S. Supreme Court decision overturning the Occupational Safety and Health Administration's revised standard on benzene a carcinogen will have a considerable impact on OSHA's efforts to tighten the asbestos standard Lowering the existing two fiber limit on workplace exposure to asbestos could create the same situation that precipitated the benzene case The Court threw out the revised benzene standard because OSHA failed to demonstrate that the lower limit was reasonably necessary to protect worker health In the benzene rulemaking OSHA relied upon its theory that no safe level of exposure to carcinogens exists The agency lowered the standard from ten parts per million of air to one part per million OSHA based its action on the assumption that a reduction in exposure might reduce the risk of leukemia associated with benzene exposure according to the Court The Court held that OSHA must show on the basis of substantial evidence that a significant risk to health exists at the higher level of exposure In the case of asbestos this ruling imposes on OSHA the burden of demonstrating a significant risk to health at the two fiber limit and that a lower level is reasonable and necessary to eliminate or lessen the risk However OSHA is not bound by the decision to support with scientific certainty a finding of significant risk A demonstration that significant risk to health is more likely than not to occur at the higher level of exposure is sufficient according to the Court Also OSHA is not required to demonstrate that the costs of the standard bear a reasonable relationship to the expected benefits because the Court deferred a ruling on the controversial benefit question That issue will be addresseidn the case of Republic Steel v OSHA next session which begins in October What the benzene ruling means is that OSHA can no longer rely on its theory that exposure to carcinogens at any level is unsafe This approach in OSHA's carcinogen policy the basis for revising the current asbestos standard must be changed to reflect the Court's directive on a finding of significant risk Thus OSHA cannot automatically lower the permissable exposure limit on asbestos to the lowest feasible level simply because asbestos is a carcinogen Instead the agency must provide substantial evidence demonstrating the need for the new level PRODUCED The Court's instructions on what evidence is required for a finding of significant risk were unclear but OSHA's attorneys have made a preliminary determination that a good study is all that is needed The study they envision would assess the risks of asbestos exposure in a workplace setting where exposure levels are known This was not the case with the benzene standard according the to OSHA From the known exposure levels OSHA could extrapolate other exposure levels under the ruling the attorney said risk to An example of what OSHA perceives to be an acceptable standard under the Supreme Court ruling is the part of the OSHA cotton dust standard applicable to textile manufacturing and textile industries The sections applicable to cotton classing and warehousing industries were suspended by OSHA July 29 because upon examination the basis for these sections may not be adequate in light of the benzene ruling OSHA decided In an attempt to respond to the court case in developing the asbestos standard OSHA staff members are in the early stages of a quantitative risk assessment and a regulatory analysis has been contracted out to the Research Triangle Institute The fourth draft of the regulatory analysis will be reviewed by OSHA next month and a final analysis may be completed by October It is unlikely that OSHA will issue its proposal on asbestos by this fall as announced last April OSHA will take time to carefully review the decision on benzene to get a clear understanding of its obligations in any new rulemaking This is not likely to be an easy task because OSHA's interpretation must be accurate enough to withstand inevitable and to other future rulemakings legal challenges to the asbestos OO standard In vieowf the current regulatory mood of Congress and the impact of the Supreme Court's decision OSHA must tread a thin line to satisfy its many critics and still achieve its objective of limiting exposure to carcinogens to the lowest feasible level PRODUCED JM- 83 oily CPSC The Consumer Product Safety Commission finally approved the general order on asbestos on May 29 1980 but it has not yet been issued The issuance of of the order in the works since August 1979 has been stalled by numerous problems and they may not be over yet For one thing the General Accounting Office still must approve the order before it can be issued The general order would require 1200 manufacturers importers and private labelers of certain consumer products containing asbestos primarily home appliances to provide the commission with informatoi n othne uses of asbestos and the firm's marketing and distribution patterns The order would not apply to the resilient flooring industry but the information requested is an example of the kind of data the CPSC might require in the future should asbestos in flooring become a regulatory target The CPSC does not consider this use as a high priority at this time The asbestos general order which survived a turf battle with the Environmental Protection Agency and a CPSC debate over the economic information to be required was originally sent to GAO on June 10 for the statutorily required review The GAO returned the order due to certain CPSC omissions such as an estimate of the time required for compliance with the order and information on CPSC consultations with EPA and industry The commission has now provided the required information and has resubmitted the order to GAO The GAO published a notice in the July 31 Federal Register requesting comments on the reporting and recordkeeping aspects of the general order Specifically the comments should address any duplication or excessive burden imposed by the order The comment period ends August 18 1980. The GAO will then have until September 8 1980 to approve or disapprove the order Whether disapproval would have any impact on the agency's ability to issue the order is a matter of debate The GAO and CPSC appear to be diametrically opposed on the issue of the commission's authority to issue the order in the face of a GAO disapproval However GAO disapproval is highly unlikely only three such denials have ever been issued In most cases the GAO and agency in question have been able to resolve the problems that arise PRODUCED JM - 83 Until the order is issued probably in September CPSC staff members will continue their preliminary efforts to develop a proposed regulation on asbestos A proposal is not likely to be issued before 1981 and a final regulation is not likely to be promulgated until late 1981 Staff members will await the information to be submitted in response to the general order before completing the asbestos proposal The products targeted for regulatory action and the approach generic or product used will depend upon the information gathered and the analyses prepared by the staff Priorities for regulation will be determined on the basis of the number of con- sumers exposed and the potential for asbestos fiber release to be taken will depend on the economic impact of regulating the risk The type of action and the nature of The commission's ability to regulate asbestos and other substances is affected by the U.S. Supreme Court's decision on OSHA's benzene standard The CPSC already is required by its mandate to demonstrate the unreasonable risk posed by a product before regulating But CPSC General Counsel Andrew Krulwich told GRC that more evidence will be needed under the Supreme Court ruling The amount of evidence needed to justify regulating exposure to carcinogens was not made clear by the Court Krulwich said However he indicated that there was nothing in the decision to prevent the CPSC from controlling exposures to low levels of a substance if the risk could be established The impact on the flooring industry of eventual CPSC action on asbestos is unclear because the commission has not yet decided which products to regulate and how It is possthi at b thelCPeSC may not regulate asbestos in flooring because potential exposure risks occur only during removal But this of asbestos nevertheless has aroused the suspicion of CPSC staffers because of the high volume of asbestos used in flooring products according to one CPSC staff member It is conceivable that the industry could accomplish a switch to asbestos substitutes before the CPSC can promulgate final regulations affecting this particular use of asbestos JFR JFR Armations Note of Amramyations acheter by PRODUCED PRODUCED PRODUCED - 83 EPA The Environmental Protection Agency's next step in the regulation of asbestos will be to propose a rule under Section a of Toxic Substances Control Act TSCA The proposal due to be published October 1980 / would require miners millers processors and importers of asbestos asbestos products to submit detailed information on asbestos fiber and asbestos products to submit detailed information on asbestos use The proposal about to undergo EPA's lengthy review process is designed to obtain information on the amount of asbestos used how it is used workplace exposures to the substance and disposal practices for asbestos waste Specific questions in the form to be filled out by respondents will address A. Asbestos Consumption 1. The total amount of bulk asbestos fiber used 2 The production quantity of items made from bulk asbestos fiber and asbestos products B. Workplace Exposure 1. The number of employees exposed to asbestos divided into categories for each plant 2 A summary of workplace exposure by weighted average for each plant C. Disposal 1. 2. 3. The form and quantity of asbestos waste An inventory of pollution control equipment and its operating efficiency a The amount of asbestos emitted into the atmosphere The information to be gathered under the Section a rule will not be used to develop a proposal for regulating asbestos under Section 6 of TSCA Chances are that the a rule won't even be made finally before the Section 6 rule is proposed in late December of early January use EPA's is for purpose in promulgating the a rule specifically addressing asbestos confirmation of the information it already has according to EPA PRODUCED- PRODUCED- 83 JM The industry reports will be used to further support and clarify EPA's anticipated action under Section 6 unless the information is significantly different from the agency's data already in hand In the latter case the final Section 6 regulation would be modified on the basis of the new data according to an EPA staff member The current shape of a Section 6 regulation on asbestos appears to be a ban on all essential uses of the fiber Such a ban would probably provide for a long lead time to permit a phasing in of alternatives by industry Essential uses of asbestos would likely be determined by an exemption process in which industries would apply for an exemption to the ban to use the reports submitted under the Section a these exemption applications It appears that EPA plans rule to help it in assessing This approach appears to address many of EPA's concerns It would reduce the economic impact of regulation by providing time for industry to switch to substitutes At the same time asbestos could still be used in cases where it is essential or where there are no practical alternatives Further the processing of exemption applications which EPA has viewed as resource intensive would be aided by the information submitted under Section a The shape of the proposal may change as EPA continues its development But whatever the outcome the proposal is likely to emphasize the role of the market- place in controlling asbestos use The theory is to set quotas or limits and then let the marketplace influence the designation of asbestos uses that are essential The specific market system selected will likely depend upon the ease of its implementation by EPA PRODUCED PRODUCED JM- 83 crs RESILIENT RESILIENT RESILIENT RESILIENTRESILIENT COVCEORVIEFNRLIGOCNOCORGOVVEERRIINNGG INSTITUTEINSTITUTE 1030 15th Street NW Washington DC 20005 Suite 350 202 833 2635 November 17 1980 TO SUBJECT Associate Members Government Affairs Report Please find enclosed a report on government activities prepared by the Government Research Corporation We feel certain that most of the items discussed are of interest to all of you As these reports are developed by GRC we plan to forward them to you on a continuing basis In this particular report we invite attention to the outlook given at the end discussed of each subject such as on page 4 which gives some insight that EPA does not intend to trace the companies responsible for selling or installing the asbestos materials in its school ceiling asbestos detection program Dale Lawson GRC Labor Policy Analyst takes a comprehensive look at asbestos compensation legislation and what lies ahead Renee Tacket calls attention to the phthalate esters investigation at CPSC which has picked resilient flooring as its first target see page 11 Hazardous wastes and the superfund are addressed by Virginia Burdick who most of you have met at the Associate Member Meetings RFCI's Board of your continuing ductive one for Directors wish to take support throughout the you this opportunity to year and that 1981 say thank you for will be a most pro- Robert Maurer Robert D. Maurer Managing Director RDM tm enclosure CC Board of Directors SuccessoTro Resilient Tile Institute ; PRODUCED JM - 83 The Government Research Corporation 1730 M Street NW Washington DC 20036 Telephone 202 857-1400 TWX 710 822-0165 GRC WSH CURRENT GOVERNMENT ACTIVITIES AFFECTING THE RESILIENT FLOOR COVERING INDUSTRY For Presentation at the Resilient Floor Covering Institute Quarterly Meeting Absecon New Jersey October 30 1980 By Renee Tackett Environmental Policy Analyst Dale Lawson Labor Policy Analyst Virginia M. Burdick Associate Director for Environmental Studies Publisher National Journal PRODUCED PRODUCED 83 TABLE OF CONTENTS Generic Rulemaking an Asbestos Le ......- ee we we we te ww Page 1 Asbestos in School Ceilings . 1... 1 1 ww eee we ee ee see 3 Asbestos Standard ees 5 rr . Asbestos Compensation Legislation Se ee es eee 6 CPSC 1... eee rr rr Ce ee 10 Hazardous Waste ... ... 12 Superf 6 ewu en e ed e ee tee A 14 PRODUCED JM - 83 GENERIC RULEMAKING ON ASBESTOS Renee Tackett The Environmental Protection Agency is running behind schedule with its strategy for generic asbestos regulation under the Toxic Substances Control Act EPA's next step in the regulation of asbestos delayed primarily because of EPA's adjustment to a new chain of reviews is to propose a rule under Section a of TSCA The proposed rulemaking which was to be published this month will not be promulgated until the end of November or the beginning of December Section a of TSCA states that EPA can require recordkeeping and reporting of information about any aspect of manufacturing and processing of a substance The rule on asbestos would require miners millers processors and importers of asbestos fiber and asbestos products to submit to EPA detailed information on asbestos use The purpose of the proposal is to obtain information on workplace exposures to asbestos disposal methods for asbestos waste and how much asbestos is used and how The information gathered under the Section a rule will be used to confirm and update data EPA already has about asbestos use The data will not be used to develop a proposal for regulating asbestos under Section 6 of TSCA Section 6 enables EPA to restrict chemical processing limit quantities that can be used require appropriate labels and mandate recordkeeping Chances are that the Section 6 rule will be proposed in late spring or early summer before the a rule has even been made final There has not been a final decision on the shape of a Section 6 regulation on asbestos but EPA is considering three possible approaches First and most likely to be approved is a ban on all essential uses of the fiber Second is a ceiling on fiber use and last a labelling requirement in conjunction with one of the other two options Any of these options probably would include a long lead time to allow phasing in of alternatives by industry Should the first option be enacted as is likely essential uses of asbestos would be determined by an exemption process allowing industries to apply for an exemption to the ban EPA plans to use the information submitted under the a rule to help in assessing these exemption applications Exemptions from the a rule will fall in areas in which EPA already has an adequate data base or under the small business DUCED tion JM - 83 -2- The essential ban is seen as the best bet for both EPA and industry for several reasons It would reduce the economic impact of the regulation by providing time for industry to switch to substitutes and asbestos still could be used in cases where it is essential or where there are no practical alternatives Also the processing of exemption applications would be accelerated by data submitted under a Outlook The thoroughness EPA is displaying has put its rulemaking on asbestos behind schedule However EPA is placing the emphasis on the initial steps in this rulemaking attempting to achieve with the other agencies regulations that are comprehensive yet nonduplicative So although the rulemaking is off to a slow start EPA hopes its thoroughness will pay off and both rules will speed through the remaining steps once they are proposed The thrust of the final rulemaking will give industry an active role in determining asbestos use both by contributing to and updating information EPA already has about asbestos and by participating in the exemption process Also of interest Before the end of the year EPA hopes to have available a conference report on the Asbestos Substitutes Conference held in July by EPA and the Consumer Product Safety Commission - PRODUCED JM - 83 -3- ASBESTOS IN SCHOOL CEILINGS Renee Tackett The Environmental Protection Agency and the Department of Education September 17 proposed a school asbestos inspection notification and recordkeeping program EPA initiated the rulemaking under Section 6 of the Toxic Substances Control Act after determining that its Technical Assistance Program TAP a voluntary inspection program for asbestos in school ceilings had not been wholly effective Asbestos a major component of resilient floor covering has been the subject of widespread controversy because of its use as a flame retardant and insulator in the ceilings of the nation's schools Because possibly 40 percent of the nation's schools have not yet taken steps to identify friable containing materials under TAP officials have determined that regulatory action is necessary EPA's proposed rules are to be used in conjunction with regulations proposed by the Department of Education which outline procedures for state and local school authorities to follow in qualifying for financial assistance and in carrying out the inspection and notification program EPA has divided its asbestos school regulatory program into two parts to expedite the elimination of asbestos in the classroom The identification and notification program proposed last month is part one EPA intends to proceed with rulemaking on part two an assessment and abatement program before part one is completed so school authorities can take corrective actions where necessary without delay EPA had expected promulgation of part two before the end of this year however because of some tough questions that have yet to be resolved this probably will be delayed several months into 1981 Promulgation of an abatement rule is awaiting completion of EPA's investi gation into several technical issues relating to corrective actions for friable containing materials By the time the schools have completed the identification stage of their asbestos programs - which could take up to nine months because of the limited availability of analytic laboratories and because of the time contraints under which schools operate -- EPA will have completed its technical investigations and be ready to roll with part two of the pro- JM - 83 -4- EPA's cost estimate for the identification and notification program is 5.2 million to be paid by the school districts until the Department of Education can set up and get funds for its 50 percent subsidy grant and loan program authorized by Congress last May under the Asbestos School Hazard Detection and Control Act of 1980 Outlook Outlook Efforts will not be made to trace the companies responsible for selling or installing the asbestos materials although an earlier advance notice had suggested this action EPA explained that determining which companies installed sold or purchased the asbestos materials installed in more than 10,000 schools between 1954 and 1973 would present insurmountable difficulties its EPA does not investigative anticipate any rulemaking within the coming year to extend and corrective measures to cover asbestos used in ceilings of buildings other than schools Although the extent of asbestos used in other public buildings already is being studied further action if any will not be taken until the conclusion of the school asbestos program PRODUCED JM - 83 ASBESTOS STANDARD Dale Lawson The Supreme Court decision on the benzene standard could affect both the nature and the timing of the asbestos standard The Supreme Court in the benzene ruling argued that before OSHA can act to change a standard it must be able to demonstrate that significant risk exists in the old standard and benefits will result from the new standard The OSHA carcinogen policy theory that there is no safe exposure to a carcinogin which is the basis for the asbestos standard will probably have to be reconsidered in view of the courts findings OSHA sources indicate that they plan to issue an advance notice of proposed rulemaking in November The comments generated by the notice and existing data will then be used to develop a proposed standard OSHA sources suggest that in view of the court ruling it may not be possible to set the exposure standard at the lowest level feasible .5 fiber per cc Although the lack of response data at the existing two fiber level is viewed as a problem OSHA believes enough data from high exposure levels and other sources will enable the agency to lower the existing standard PRODUCED JM - 83 ASBESTOS COMPENSATION LEGISLATION Dale Lawson The latest effort to promote asbestos disease compensation legislation resulted in a bill S 2847 sponsored by Gary Hart Colo which was politely although not too seriously received by the Senate Labor and Human Resources Committee during August hearings on coverage of three single occupational diseases O Committee Chairman Harrison Williams NJ opponent of the single disease approach to D compensation reportedly held the hearings out of courtesy to the bill's sponsors rather than out of genuine interest in pursuing disease- specific compensation The bill was largely the product of Hart's staff and of representatives of Manville one of the largest asbestos manufacturers Also working on the measure was the leadership of the Asbestos Workers one of the smallest unions representing asbestos workers Although little criticism was heard from other unions and employers who disagreed with the bill their silence was largely due to confidence that the bill would not move significantly forward at this time The bill would ease somewhat the eligibility standards for claimants establish minimum indexed benefit levels provide for apportionment of liability and prohibit third party suits It could have a serious financial impact on RFCI members by making the last employer of an asbestos exposed worker regardless of the length and degree of exposure responsible for the base compensation award with no right of subrogation Other provisions which increase benefit levels and facilitate eligibility would have the overall impact of adding costs to the system Outlook An Asbestos Bill Although those involved with drafting the Hart bill are working on technical and minor amendments in hopes of making it more palatable it is not likely to move much farther in the legislative process The Senate Labor and Human Resources Committee does not plan further activity on the subject this Congress and there is still no sponsor for a House version As for the next Congress there is some doubt that Hart would press his bill if he wins reelection Most of organized labor has serious problems with the Hart bill but has refrained from criticizing Hart a strong labor ally prior to his closely contested election Occupational disease legislation is essentially labor legislation and will not succeed without labor support Some business supporters of S 2847 are already searching both Houses for alternate sponsors of the asbestos disease approach The search will likely be difficult however because the sponsorship role could be politically hazardous Heavy criticism was addressed to Millicent Fenwick another bill which protected asbestos manufacturers N.J who in 1979 sponsored from liability The Hart bill has privately come under even harsher criticism from unions Employer groups will have a hard time finding sponsors since most of the business community and their Congressional allies oppose federal involvement in workers compensation regardless of the disease Another possible source of asbestos compensation legislation is Rep George Miller Calif an outspoken critic of the asbestos industry Miller has indicated an interest in introducing asbestos compensation legislation but has not discussed its content except to say that his bill will allow third party suits against manufacturers Given Miller's pro labor voting record and ongoing feud with Manville his bill can be expected to facilitate claimant success at the expense of the major manufacturers Still another source of asbestos compensation legislation could come from the efforts of a coalition of unions academics and attorneys closely associated with the victims of asbestos diseases Legislation likely to be developed by this group would focus on developing federal standards which would open up the compensation system to asbestos disease claimants and eliminate to the extent possible the adversary system Sources indicate that this group is leaning away from third party suits in exchange for the reforms just mentioned Congres- sional sponsors have not yet been sought because this effort is still in the formative stages but finding sponsors will not be difficult once the effort PRJOMDU8C3E - underway Comprehensive Legislation Single disease bills are expected to be introduced next year but are unlikely to succeed in the near future because key congressional and labor supporters remain opposed to the piecemeal approach It is possible though unlikely however that another year of failure to make progress towards comprehensive legislation could force certain unions and members of Congress to reexamine the practicality of the comprehensive efforts The most likely direction of congressional action in the next Congress is toward federal involvemie n nthte compensation of all occupational diseases Legislation proposed in both bodies ov the e lr ast eight years have included federal standards for compensating both occupational disease and traumatic injuries Efforts may be limited to D in 1981. Eliminating traumatic injury would reduce the costs of federal standards possibly soothe state worker's compensation W administrators and target the most serious failure of the state W system e.g. occupational disease This possibility will depend on both Chairman Williams and House Education and Labor Subcommittee on Labor Standards chairman Ed Beard R.I returning to their respective positions On the House side Beard's staff is preparing draft legislation which would federalize the D compensation system rather than establish federal standards for state systems Beard believes that states are both unable and unwilling to adequately handle the D problem The bill is still in the formative stages but is known to 1 establish a federal D administration 2 create a central fund partially financed by employers from which claims would be paid 3 establish a list of compensable diseases and 4 allow the use of rebuttable presumptions This proposal has only lukewarm union support at present but support is growing Unions favor the ultimate federalization of the system but believe it is politically impractical given the fact that the less ambitious and controversial federal standards bills have not made it out of subcommittee in eight years Federalization will be strenuously opposed by employer and insurance groups on states rights and other grounds Beard may introduce a federal standards bill as a fall back position Should Beard lose the election or his chairmanship House efforts will probably be directed towards comprehensive federal standards Sen. Williams is considering introducing a federal standards bill for D only which would leave program administration to the states Other provisions 23 PRODUCED JM JM would most likely follow the patteronf his earlier bills and liberalize elibibility requirements raise benefit levels and streamline administration Some of organized labor is trying to persuade the Senator to keep traumatic injury in his bill while others favor the focus on D Should Sen. Williams lose his election or chairmanship efforts will most likely shift back to comprehensive federal standards legislation Legislative activity is likely to begin as early as the first session of the next Congress but it is not likely to be completed until the economy recovers The extremely high and unpredictable costs of any of the described proposals would add to inflation at a critical time The Carter White House at OMB's urging is not encouraging any kind of federal legislation and has in fact restricted high level Labor Department participation in developing proposals A Reagan administration or Republican leadership of Congressional Committees would hamper efforts to establish a federal role in the W -O system PRODUCED CPSC Renee Tackett Asbestos The Consumer Product Safety Commission still has not issued its general order on asbestos although the Commission approved the order last May In the works for well over a year now the order has been stalled by numerous problems The latest hang has been with the General Accounting Office's statutorily required review As required GAO published a notice in the Federal Register in July seeking comments on CPSC's order When the comment period was over CPSC had 45 days to respond to comments Apparently the task was too great to complete in the given time so CPSC and GAO stopped the clock on the project CPSC's review of the comments was given to GAO only this month CPSC expects GAO to accept the review this time around although a few minor changes may have to be made Still the general order on asbestos should be published in the Federal Register before the end of the year The general order would require 1200 manufacturers importers and private labelers of certain consumer products containing asbestos primarily home appliances to provide the commission with information on the uses of asbestos in their products and the firms marketing and distribution pattems CPSC is not concerned with the use of asbestos in resilient floor covering at this time but the information requested were it to become a regulatory target would be the same The information CPSC gathers under the general order will be used to develop regulations in the future probably of specific products There is no effort afoot at CPSC to take EPA's broad brush approach to asbestos a product approach is much more likely than any generic rulemaking by CPSC However the policy will not officially be set until information is returned under the general order Despite the hold with the general order CPSC expects to be putting its words into action long before EPA does anything concrete with its rule- making on asbestos Already CPSC staffers are preparing a package on asbestos paper in response to a petition filed last April A proposed rulemaking an asbestos paper is expected to be published before the end of the year PRODUSEEPRODUSEE 83 Outlook -11- Priorities for regulation will be determined on the basis of the number of consumers exposed and the potential for asbestos fiber release The type of action to be taken will depend on the economic impact of regulation and the nature of the risk Right now CPSC appears to be more concerned with the politics of getting its general order through the bureaucracy than with determining which products to regulate Even when CPSC does begin the process of investigating specific products the inert property of resilient floor covering probably will give CPSC cause to pass over it and look into household appliances which directly expose consumers to asbestos fibers Phthalate esters CPSC soon will be taking a close look at the use of plasticizers in the resilient floor covering industry Phthalate esters used to make many plastic products including flooring flexible are on CPSC's priority list for 1981 Although not much information is in yet CPSC suspects that some of the 10 different kinds of esters may be carcinogenic Of the two esters that already have been tested one is not clearly carcinogenic and the other has been found to be carcinogenic in male and female rats and mice Testing already has begun on the other eight esters Major consumer product uses of esters include vinyl flooring food wraps tubing for intravenous injections and insulation on electric wiring Polyvinyl chloride is made pliable by means of the esters which is probably the main reason that CPSC has chosen floor covering as its first target Although CPSC has not settled on additional studies following the tests for carcinogenicity sometime within the next year CPSC hopes to determine whether esters in consumer products can be released in large enough amounts to pose a risk to the public or whether the large cumbersome particles can be released at all On the bright side for RFCI esters are designed not to be released in order to maintain a product's pliability PRODUCED JM - 83 -12HAZARDOUS WASTE Virginia M. Burdick As one of its final acts before adjournment in October Congress approved and sent to President Carter delayed legislation S 1156 reauthorizing the Resource Conservation and Recovery Act RCRA The reauthorization measure contains several important amendments to the hazardous waste regulation program adopted earlier this year by the Environmental Protection Agency Many of these amendments are aimed at making the hazardous waste regulations less burdensome for industry One amendment in particular is likely to affect some members of RFCI This amendment pertains to regulation of site pits ponds and lagoons that are used to treat or dispose of hazardous waste Many of these lagoons were installed to comply with the Clean Water Act When EPA first proposed its hazardous waste regulations under RCRA the agency would have required costly retrofitting of pits ponds and lagoons to make them watertight Industry argued that it was unfair to make the requirements more stringent for these facilities after issuing permits for them under the Clean Water Act This dispute arose primarily because the Clean Water Act applies only to surface waters while RCRA is aimed at protecting groundwater Lagoons installed to comply with the Clean Water Act sometimes are not sufficiently watertight to prevent discharges into groundwater because they were only designed to prevent discharges into surface waters In response to industry's objections both the Senate and House versions of the RCRA reauthorization legislation eased up on the retrofitting require- ments for industrial pits ponds and lagoons The final version approved by Senate conferees represents a middle ground between the House and the Senate versions The conference agreement requires the EPA administrator to distinguish between new and existing pits ponds and lagoons when regulating these facilities under RCRA What this means is that new pits ponds and lagoons will have to be made watertight but existing lagoons will not necessarily be subject to this requirement across the board Outlook Outlook According to congressional sources clarify that retrofitting of pits ponds unless there is evidence that leakage is the conference report language will and lagoons should not be required PRODUCED causing damage to groundwater PRODUCED 83 -13- The legislation and the accompanying report language therefore could substantially ease the impact of the RCRA regulations on RFCI companies that use pits ponds and lagoons for waste disposal or treatment The extent of the relief will of course depend on the way EPA interprets and enforces the amendment PRODUCED JM - 83 -14SUPERFUND Virginia M. Burdick t 4 Congress has made substantial progress on superfund legislation in recent months but many important issues remain to be resolved Therefore it is extremely unlikely that Congress will be able to complete action on a superfund bill during the lame duck session after the election That means that the new Congress will start out fresh on this controversial issue Superfund legislation would have an important if indirect impact on RFCI members because of the new costs it would impose on the chemical industry These increased costs would be passed down to manufacturers such as the members of RFCI and ultimately to consumers The superfund bills being considered by Congress would create industrysupported funds to pay for clean and victim compensation costs associated with oil spills hazardous chemical spills and abandoned hazardous waste site discharges In addition the bills would impose new liability burdens on industry Here is a brief rundown of the current status of superfund legislation in the House and Senate e HR 85 which would establish a 750 million fund to deal with oil spills and hazardous chemical spills was approved by the House on September 19 by a vote of 288-11 and is now pending in the Senate e HR 7020 establishing a 1.2 billion superfund to take care of abandoned hazardous waste sites was passed by the House 351-23 on September 23. It too is pending in the Senate e@ $ 1480 the Senate's version of superfund legislation is now pending before the Senate Finance Committee Earlier it was approved by the Senate Environment and Public Works Committee This bill would create a 4.2 billion fund to deal with abandoned waste sites and hazardous chemical spills and is far more stringent than either of the House bills mentioned above Outlook There is little likelihood that the Senate will be able to complete action on S 1480 during the lame duck session The Senate Finance Committee has asserted jurisdiction over the funding provisions of the bill as did the House Ways and Means Committee and has agreed to finish its markup by November 21. Even if Finance meets this deadline that would leave litPRODUCED JM - 83 -15- time for Senate floor action and subsequent action by a Senate conference committee So it looks as though superfund legislation will be off to a fresh start next year in what could well be a substantially more conservative political climate GRC is predicting that superfund legislation eventually will pass but in 1982 at the earliest PRODUCED JM - 83 UM Manville Internal Correspondence To ALL SALES REPS From J. E. Connor - WHQ 2-13476 Copies Ed Day >> Jeffrey W. J. Plichta - Research Subject RFCI WORK PRACTICES Date July 8 1980 Attached is a copy of their announcement We have ordered additional copies and will mail one to you when we receive our supply Connor E. Connor Attach RESIFLLOOIR ENT COVERING INSTITUTE Washington 202 833 2635 RFCI For Immediate Release RFCI ISSUES INSTALLERS WORK PROCEDURES MANUAL Washington D.C. July 1 1980 - The Resilient Floor Covering Institute has just published its Recommended Work Procedures for Resilient Floor Coverings The manual covers containing products produced by RFCI member companies and outlines important information for installers in handling the products on the job The work procedures outline the safety precautions which should be taken when installing and removing resilient floor coverings said RFCI President Jack Clegg Vice President of Kentile Floors Inc. We emphasize proper removal of vinyl asbestos tile asphalt tile and sheet vinyl products with asbestos backings continued Clegg We do not recommend sanding of these products nor scraping of asbestos felt he concluded Single copies the Recommended Work Procedures For Resilient Floor Coverings are available free from the Resilient Floor Covering Institute 1030 15th St. NW Suite 350 Washington D.C. 20005 Successor To ResiTl ileiIe nstn itut te -30- PRODUCED JM - 83 a= . JM Manville Internal Correspondence To ALL SALES REPS From J. E. Connor - WHQ 2-1347c Copies Ed Day - Jeffrey W. J. Plichta - Research Subject RFCI WORK PRACTICES Date July 8 1980 Attached is a copy of their announcement We have ordered additional copies and will mail you when we receive our one to supply Be + E. Connor Attach Bcc Note to R.J.H. I sent the : and a announcement announcement| copy of the | manual to Jack Wilkinson PRODUCED PRODUCED e Washington 20005 nege , RESILIENT DC FLOOR _ 202 833 2635 Suite 350 ~ etre COVERING Pitan INSTITUTE RFCI For Immediate Release RFCI ISSUES INSTALLERS ze WORK PROCEDURES MANUAL Washington D.C. July 1 1980 - The Resilient Floor Covering Institute has just published its Recommended Work Procedures for Resilient Floor Coverings The manual covers containing products produced by RFCI member companies and outlines important information for installers in handling the products on the job The work procedures outline the safety precautions which should be taken when installing and removing resilient floor coverings said RFCI President Jack Clegg Vice President of Kentile Floors Inc. We emphasize proper removal of vinyl asbestos tile asphalt tile and sheet vinyl products with asbestos backings continued Clegg We do not recommend sanding of these products nor scraping of asbestos felt he concluded ah taken Single copies of the Recommended Work Procedures For Resilient Floor Coverings a are available free from the Resilient Floor Covering Institute 1030 15th St. NW Suite 350 Washington D.C. 20005 -30- Successor To Resilient Tile Institute PRODUCED 83 Manville Corporation Caryl Ranch Denver Colorado 80217 303 979-1000 Executive Offices f May 27 1980 Mr. Robert D. Maurer Resilient 1030 15th Suite 350 Floor Covering St. N.W. Washington D.C. 20005 Institute Dear Bob Thought the attached might be of interest to your members The only interpretation that I can make of EPA's statements on pages that the one use a hazard and two is that they have omnipotently decreed of vinyl asbestos floor tile does not present I would suggest that your members manufacturing asbestoscontaining floor tile advertise that it is not a hazardous product as judged by EPA Unfortunately manufacturers of floor tile using substitutes cannot make this statement Best regards Very truly yours JFR tw Attachment James F. Reis Director Asbestos Policy bcc So a 7 J. E. Connor 2.13 2.13 D. M. Kelleher Nea Environmental Protection Agency Toxic Substances 793 Washington DC 20460 Toxics Information Series Asbestos -- What Is It Why Is Asbestos A Problem Asbestos was once considered a health risk only for asbestos workers Now asbestos is known to be a potential hazard to the health of millions of people on and off the job who are routinely exposed to asbestos fibers in the air they breathe Among those whose health may be endangered by asbestos are children teachers and others in schools where asbestos was sprayed or troweled on ceilings rafters beams and other structural building parts for proofing insulation sounddeadening or decoration This Information Bulletin discusses the asbestos hazard and what the U.S. Environmental Protection Agency EPA is doing to help safeguard public health from the risks of asbestos Asbestos is the common name for a group of natural minerals -- silicates -- that separate into thin but strong fibers The fibers are chemically inert and heat resistant and they cannot be destroyed or degraded easily These characteristics have made asbestos very useful commercially Asbestos is widely used for proofing and insulating homes and all kinds of public and private buildings Asbestos products include reinforced asbestos cement sheets and pipes pipe insulation roofing felt and shingles floor tiles patching and taping compounds brake linings clutch facings insulating paper and protective clothing Some 800,000 tons of asbestos are mined or processed in the U.S. each year to make about 3,000 different products thirds of which are used in the construction industry Unless it is completely sealed into a product as in asbestos floor tile asbestos can easily break into a dust of tiny fibers These fibers much smaller and more buoyant than ordinary dust particles float almost indefinitely in the air and can easily be inhaled or swallowed Once fibers enter the body they can cause a number of serious diseases Asbestosis a chronic disease of the lungs which makes ing more and more difficult and can cause death breath- Cancer Breathing asbestos fibers definitely can cause lung cancer Also since some of the asbestos fibers are rejected by the lungs move up to the throat and are swallowed breathing asbestos can also cause cancer of the esophagus stomach intestines and rectum PRODUCEPDRODUCED - 13 13 JM -~ . . Core ne appinaee eee met Mesothelioma a cancer of the membranes that line the chest and abdomen Mesothelioma almost never occurs in people who have not been exposed to asbestos It is always fatal Once asbestos gets into the body it remains there in- definitely It can move from the lungs to almost all other parts of the body including the brain and the sex organs Cancers can occur anywhere from 15 to 40 years after the first exposure No safe limit or threshold of exposure : is known Any exposure to asbestos carries some risk to health and people exposed to low levels of asbestos for a very brief period have later contracted mesothelioma Finally anyone exposed to asbestos who also smokes cigarettes has five times the chance of contracting lung cancer than a cigarette smoker who has not been exposed to asbestos What's The Government Doing About This Health Hazard The Occupational Safety and Health Administration has established limits for worker exposure to asbestos on the job The Food and Drug Administration is responsible for making sure that foods drugs and cosmetics are not con- taminated with asbestos And the Consumer Products Safety Commission CPSC regulates asbestos in consumer products it has already banned the use of asbestos in ceramic logs in fired fireplaces in consumer clothing and in drywall patching compounds CPSC is studying the extent of asbestos use in all consumer products and is considering banning all essential uses of asbestos in consumer products that can release asbestos fibers EPA which among other authorities regulate air and water contamination by asbestos prohibited the spraying of asbestos materials for proofing and insulation in 1973 banned the use of asbestos that can crumble in pipe and boiler coverings in 1975 and prohibited virtually all uses of sprayed asbestos materials in 1978 In addition EPA is investigating the cumulative effects on public health of exposure to asbestos -- from the time it is mined and milled through processing and product manufacturing use and disposal And EPA is also considering banning all essential uses of asbestos and asbestos products The prohibitions being considered would be phased in over a period of time and would exempt certain essential uses for which reasonable substitutes do not exist and which do not pose an unreasonable the possible exemption from for firemen if the asbestos risk to health One example of the ban protection suits is totally enclosed sealed or sawee e e Not All Asbestos Products Are Hazardous Asbestos becomes a health hazard only when fibers are released into the air This usually happens when the asbestos materials can be crumbled in the hand -- in technical language when the asbestos material is friable as is asbestos insulation sprayed on a ceiling In contrast vinyl asbestos floor tile is not generally friable The asbestos fibers are firmly bound or sealed into the tile and can be released into the air only if the tile is cut ground or sanded PRODUCED 7 PRODUCED What About Asbestos In Schools bonded into the suit so that no asbestos fibers can be re- leased into the air Under the Toxic Substances Control Act EPA is required to ban or limit the use and disposal of any chemical substance that poses an unreasonable risk of injury to human health or the environment Preliminary studies show that millions of people may indeed be facing the danger of unreasonable risk to their health from asbestos particles from an increasing number of sources Thus the contemplated regulations to prevent and reduce unreasonable risks from asbestos Teer Between 1940 and 1973 hundreds of thousands of tons of asbestos were sprayed or applied on ceilings and other parts of many schools -- and other buildings public and private -- for fire- proofing deadening insulation or decoration Surveys indicate that 5-15 percent of the nation's public schools contain some asbestos materials Some of the asbestos material is now known to be damaged or deteriorating -- and releasing asbestos fibers into the air in the buildings The fibers can remain suspended in the air for hours And fibers that settle to the floor can be stirred up into the air again as children walk or run through halls classrooms the gymnasium the cafeteria Thus while the asbestos fibers may be released only sporadically from damaged insulation on a ceiling or pipe there can be virtually continuous exposure to asbestos Indeed in some schools asbestos levels in the air have occasionally exceeded the Federal safety standard for asbestos workers It seems likely that the dangers of asbestos exposure are particularly grave for children Since they are exposed early in their lives asbestos cancers will , time to develop have plenty of To safeguard the health of school children teachers and others who work in schools EPA has launched a school asbestos program The purposes of this program are to identify school buildings that contain asbestos materials to inspect those buildings to see if asbestos fibers are being released into the air within the building to remove or repair the damaged asbestos materiaanld periodically to inspect the asbestos materials left in the schools NOT For Schools Alone EPA's Asbestos Guidance Package is not just for public schools Asbestos materials have been used in the construction or renova- tion of many private schools colleges universities and office commercial and residential buildings The package can help any building owner identify and eliminate asbestos hazards It's available free by calling free 800-424-9065 In the Washington D.C. area the number is 554-1404 . EPA has prepared and made available to State governments schools two manuals that explain step how asbestos problems can be identified and PRODUCEI and loca step by corrected.JM - 83 ee 3 Want More Information REGIONAL OFFICES The manuals -- called the Asbestos School Guidance Package -are available free from EPA A videotape outlining the procedures explained in is available from EPA's 10 regional offices And trained EPA asbestos coordinator in each regional the manuals a specially office can provide additional technical assistance EPA's school asbestos technical assistance program has been voluntary participated in necessary steps and many State and local governments have program However to make sure that the are taken to reduce the risk of asbestos exposure EPA plans to issue regulations requiring that elementary and secondary schools be inspected for the presence of asbestos and requiring that asbestos exposure problems be corrected 7 In sum EPA's school asbestos program has already helped some schools identify and reduce asbestos hazards and when the regulations are issued will require other schools to do so too . Meanwhile students parents teachers and other concerned citizens can help rid the nation's schools of asbestos hazards by urging their school officials to take the necessary actions if they have not already done so Tiss Additional information on EPA's asbestos program is available from EPA headquarters in Washington D.C. -- 800-424-9065 554-1404 in the Washington area -- or from EPA regional offices Additional information on the effects of asbestos on.health is available from Asbestos National Cancer Institute Bethesda Md 20205. Call 800-638-6694 in Maryland 800-492-6600 Additional information on asbestos in consumer products is available from the Consumer Products Safety Commission Call 800-638-8326 800-492-8363 in Maryland 800-638-8333 in Alaska Hawaii Puerto Rico Virgin Islands Region 1 Region 3 Mr. Paul Heffernan Asbestos Coordinator Mr. Fran Dougherty Asbestos Coordinator Air & Hazardous Materials Div Pest & Toxic Substances Br EPA Region 1 JFK Federal Bldg Boston MA 02203 EPA Region 3 Curtis Building Sixth & Walnut Streets Philadelphia PA 19106 215 597-8683 617 223-4 Region 2 Mr. Marcus Kantz Region 4 Mr. Dwight Brown Asbestos Coordinator Asbestos Coordinator EPA Region 2 Room 802 EPA Region 4 345 Courtland Street Atlanta GA 30308 26 Federal Plaza New York NY 10007 404 881-3864 212 264-9538 Region 5 Dr. Lyman Condie Asbestos Coordinator EPA Region 5 230 S. Dearborn St. Chicago IL 60604 312 353-2291 Region 6 Dr. Norman Dver Asbestos Coordinator EPA Region 6 First Internat'l Bldg 1201 Elm Street Dallas TX 75270 214 767-2734 Region 7 Mr. Woligang Brandner Asbestos Coordinator EPA Region ? 324 East 11 Street Room 1500 Kansas City MO 64106 816 374-3036 Region # Mr. Steve Farrow Asbestos Coordinator EPA Region 8 1860 Lincoln Street Denver CO 80295 313 837-392h Region 4 Mr. John Yim Asbestos Cinordinator EPA Region 9 215 Fremont Street San Francisco CA 94105 415 556-3352 Region 10 Ms. Margo Partridge Asbestos Coordinator EPA Region 10 1200 Sixth Avenu^ Avenu^ Seattle WA 98101 206 442-556U PRODUCEPD RODUCED JM - 83 1030 15th Street NW Washington DC 20005 Suite 350 FLORING RESILENT INSTUE COVERING FLOR RESILENT Recommended Installation Specifications for Vinyl Asbestos Solid Vinyl and Asphalt Tile Floorings This recommended installation procedure has been prepared by the member companies of the Resilient Floor Covering Institute listed on the back page It is intended to be used as a general guide If questions arise on any specific points it is suggested that the manufacturer of the tile to be installed be contacted All manufacturers as listed have detailed installation instructions which cover in detail requirements that may not be included in this general guide These are available from the individual manufacturer Material Specifications 1. Vinyl Asbestos Tile shall conform to the requirements of Resilient Floor Covering Institute Specifications Types I Smooth Surface and II Embossed Surface or Federal Specification 312 Type IV Under these specifications Vinyl Asbestos Tile is available in 12 x 12 size and in nominal thicknesses of 1/8 3/32 .080 and 1/16 2. Solid Vinyl Tile shall conform to the requirements of Resilient Floor Covering Institute Specifications Type I Smooth Surface and Type II Embossed Surface or Federal Specification 312 Type III Under these specifications Solid Vinyl Tile is available in 12 x 12 size and in nominal thicknesses of 1/8 .080 1/16 050 and .039 3. Asphalt Tile shall conform to the requirements of Resilient Floor Covering Institute Specifications Types I Smooth Surface and II Embossed Surface or Federal Specification 312 Type I. Under these specifications Asphalt Tile is available in x " size and in nominal 1/8 thickness 4. Adhesive Asbestos Tile and Asphalt Tile are usually installed with an Asphalt Water Emulsion Adhesive RFCI Specification Type 1 Class 1 or 2 and Federal Specification MMM or an Asphalt Back Adhesive RFCI Speciications Type II and Federal Specification MMM or with Water Based Latex Different types of Solid Vinyl Tile may require special adhesives Consult the individual tile manufacturer for the recommended adhesive for a specific product and installation Adhesives RFCI Specifications Type II CAUTION Solvent adhesives such as Asphalt Back are flammable Refer to instructions on container labels for precautions 5. Lining Felt be 15 lb. fully saturated asphalt flooring felt Follow the recommended suggestion of the the tile to be used as regards use of lining felt on the floor to be covered Linoleum Paste is forcementing lining felt to wood floors Eh: 6. Protective Edgings are used to prevent tripping and damage to the installed tile edges They are available in a variety of shapes and materials To function properly protective edgings shall be securely fastened to the floor General Specifications Installation Vinyl Asbestos Solid Vinyl and Asphalt Tile are thermoplastic materials and will follow the contour of the floor to be covered The smoother the floor the better the finished tile floor 1. Installation shall not begin until the work of all other trades has been completed and the area cleared of extraneous materials If job requirements are such that the tile must be installed before other trades have completed their work the installed tile shall be covered with heavy paper or other suitable protective coverings excluding saturated felt PRODUCEDPRODUCED ; JM - 83 2. All rooms tile and adhesive shall be maintained at a minimum temperature of 70 for at least 48 hours before during and 48 hours after application of the tile 3. Spread adhesive eventy and at the rate of coverage recommended by the tile manufacturer using a notched steel trowel or other devices as may be specified by the manufacturer of the tile and adhesive When back the adhesives are used proper safety measures regarding ventilation open flames and other precautionary requirements noteodn the container label must be followed 7 4. Tile shall be laid starting at the center of the room and working toward the walls By the preferred practice tile is 4 laid starting at the center of the room working toward the walls however other acceptable commercial practices can be substituted as the starting point starting point shall be adjusted as required to provide a border width equal to at least a half tile width Border tile shall be scribed to the wall cut and fitted into place after the field tile has been applied Concrete Floors Suspended Grade or Grade Vinyl Asbestos Solid Vinyl and Asphalt Tile shall be installed directly to concrete floors without the use of lining felt Concrete floors shall be of a standard mix as recommended by the Portland Cement Association Radiant Heated Floors Vinyl Asbestos Solid Vinyl and Asphalt tile may be installed over radiant heated concrete floors provided that the heating system is properly controlled to give a maximum temperature of 85 measured directly over the heating pipes In addition all furniture must be equipped with the proper load bearing devices casters glides furniture cups as specified by the Resiliant Floor Covering Institute New Concrete Floors es. A New concrete floors which are on or below grade require a drying time of at least 4 to 6 weeks On this type of - construction the use of a waterproof membrane such as a 4 or 6 mil polyethylene membrane installed between the concrete and ground is recommended Suspended concrete floors require a drying time of at least 3 weeks after the concrete forms are removed If the suspended concrete has been installed over metal decking additional drying time will be needed The floor shall be steel trowelled to a smooth plane surface free from score marks grooves or depressions scraped free of all foreign material and brushed clean CAUTION Concrete curing and tilt up parting compounds are not recommended If the use of such compounds are ewe specified the tile manufacturer must be consulted in advance Some compounds can prevent proper tile adhesion to the floor or may cause term installation failure . Old Concrete Floors ee a Old concrete floors shall be clean and free of oil grease wax or dust Oil base paints must be removed from old on or below grade concrete floors An effective way to do this is with a drum sander followed by a thorough rinsing with clear water After rinsing the floor must be allowed to dry before installing Vinyl Asbestos Solid Vinyl or Asphalt Tile If the floor has been painted with a rubber base paint the paint need not be removed provided it is well bonded to the concrete floor^- If the type of household fint is unknown a simple test may be made using a solution of one ) tablespoon of household . lye in a cup of warm Place small puddles of the lye solution at various spots on the painted floor If the paint has not dissolved softened or peeled from the floor in 30 minutes Vinyl Asbestos Tile or Asphalt Tile may be installed without removing the paint When preparing and using a lye solution be sure to read and carefully follow the instructions and precautionary measures on the lye container b For the installation of tile over existing floor coverings consult the tile manufacturer's recommendations Existing floor coverings having a foam cushion or cushion layer and an embossed surface must be removed c Rough or uneven concrete floors above on or below grade must be smoothed before tile application A two part patching compound commonly identified as latex underlayment is recommended If the area to be smoothed is excessively large contact the tile manufacturer for suggestions as to the best way to do this at the lowest cost Light Weight Concrete with a density of less than 100 lbs per cubic foot is not a satisfactory floor for Vinyl Asbestos Tile or Asphalt Tile Light weight concrete of less than the required density must be covered with layer of standard concrete mix C Wood Suspended Wood floors over which Vinyl Asbestos Solid Vinyl or Asphalt Tile are to be installed must be solid well nailed at joists and from springiness All wax grease dirt and dust shall be removed to insure proper adhesive bond Vinyl Asbestos Solid Vinyl or Asphalt Tife shall not be installed over wood floors in contact with the ground Wood floors which are located over a crawl space are satisfactory if the crawl space has a minimum of 18 inches of cross ventilated air space between the ground and the floor joists Note A moisture barrier heavy asphalt saturated felt paper or polyethylene film laid on the ground with overlapped widths or lengths is effective in controlling high humidity due to ground moisture The moisture barrier is not a substitute for cross ventilation a Double Wood Floors Loose or broken boards shall be renailed or replaced and the floor sanded to correct irregularities such as warped or cupped boards Install 15 lb. asphalt saturated felt paper on suspended double wood floors with top boards less than wide Cement the felt paper across the boards using linoleum paste Butt the edges of the felt do not overlap and roll with a 150 lb. roller rolling from center to edges to insure a good bond and to eliminate trapped air If the double wood floor is in poor condition which sanding will not correct or if the top boards are more than wide install Underlayment Grade plywood fully sanded minimum thickness with face grain perpendicular to board joints or use underlayment hardboard In areas that may be subjected to excessive surface moisture use Underlayment Grade plywood bonded with exterior glue of C plugged and sanded exterior grade plywood If specifically recommended by the tile manufacturer 1/4 Service Class Underlayment grade Hardboard meeting the requirements of U.S. Product Standard PS58 7m3ay be used instead of 1/4 plywood Unless otherwise recommended by the tile manufacturer the hardboard shall be installed smooth side up Install the plywood or hardboard underlayment with cross joints staggered at least 16 Use ring grooved annular nails screw nails divergent staples spaced 6 on center throughout the board and spaced apart along the edges Fasteners shall penetrate at least 1-1 into the floor Nail center of board first working out to the edges Leave a space between underlayment sheets equal to the thickness of a dime Drive fasteners flush or set not more than 1/16 below the surface It is necessary to fill nail holes if fasteners are below the surface of the underlayment Lightly sand any roughness particularly at joints and around nails Follow tile manufacturer's instructions regarding the use of 15 lb. asphalt saturated flooring felt paper over plywood or hardboard underlayment b Single Wood Floors Single wood floors shall be covered with 1/4 minimum thickness Underlayment Grade plywood where the floor boards are 4 or less in width If the floor boards are more than 4 wide install 1/2 Underlayment Grade plywood The plywood face grain shall be perpendicular to the joists Follow the same nailing procedure as outlined in a above c Open Wood Joists Install 5/8 Underlayment Grade plywood where joist spacing is 16 or less For joist spacing up to 24 use 3/4 plywood Blocking or bridging is required under the plywood along the edges perpendicular to the joists Face grain of the plywood shall be perpendicular to the joists Nail with ring grooved annular nails screw nails or divergent staples which will penetrate 1-1 into the joists Space nails 6 apart over the joists and or set not more the below the surface apart along the edges Drive the nails flush d 2 4 11 2 Plywood Installation 2 4 Tong1ue and Groove plywood is a combination underfloor and underlayment plywood panel No blocking or bridging is required when properly installed over open wood joists spaced 48 or less on center 2-1 ring grooved annular or screw type nails or divergent staples spaced on center at all bearings shall be used Drive the nails flush or set not more than 1/16 below the surface It is necessary to fill nail holes if fasteners are below the surface of the underlayment Note This specification is not intended to cover the use of tempered hardboard particleboard or any underlayment boards other than those specified above Note Plywood shall meet the requirements of U.S. Product Standard PS 1-74 See Guide to Plywood Grades published by American Plywood Association for further details on recommended plywood underlayment Note 2 4 pl1ywood shall meet the requirement of U.S. Product Standard PSI See Guide to Plywood Grades published by American Plywood Association for further details on 2-4-1 plywood PRODUCED JM - 83 GENERAL RECOMMENDATIONS a Prevention of Indentation All metal domes shall removed from the legs of furniture and equipment Suitable protective devices as recommended by the Rediffent Floor Covering Institute shall be used on furniture or equipment to protect against indentation Copies of the RFCI recommendations are available upon request b Maintenance The frequency with which a floor should be swept scrubbed buffed or waxed will vary with the amount of traffic To insure proper maintenance recommendations of the tile manuacturer should be followed These are available upon request from all manufacturers The Resilient Floor Covering Institute has literature on maintenance featuring wax and regular maintenance procedures Copies are available upon request c Floor Finishes Many of the newer types of floor polishes being marketed toda^form tough moisture impermeable films These films are not readily removed by normal means While this may be desirable from a maintenance point of view it can create conditions detrimental to the tile Continued use of these tough film polishes without periodic stripping will result in an accumulaiton of a thick layer of polish on the tile surface In some cases this film is strong enough to cause the tile edges to curl Planned stripping of polish coatings is an important part of floor maintenance Floors should be stripped after every three or four polish applications This can be best accomplished by adding a cup of household ammonia to a bucket of water with the recommended floor cleaner followed by thorough rinsing of the floor Stripping old polish regularly will prevent such problems as yellowing and dirt build in the polish coating d Use Doors Vinyl Asbestos Tile or Asphalt Tile shall not be used doors Some types of Solid Vinyl Tile are recommended for outdoor installation Consult the individual manufacturer for recommendations as to product and adhesive e Magnesite Floors Consult the tile manufacturer for specific instructions if Vinyl Asbestos Solid Vinyl and Asphalt Tile is to be installed over magnesite floors TILE PRODUCING MEMBERS OF RESILIENT FLOOR COVERING INSTITUTE AMTICO FLOORING DIVISION American Biltrite Inc. AZROCK FLOOR PRODUCTS Uvalde Rock Asphalt Company KENTILE FLOORS INC INS78 FLINTKOTE COMPANY Flooring Products Division GAF CORPORATION Consumer Products Group NATIONAL FLOOR PRODUCTS COMPANY