Document rxrK2m6wL52gQEGGBM4m808jG

The Ministry of Labour and Lationol rectory -oparttcent, 5t- Jure5's fquare, LcnJon, 3.U.I. Dear Sirs, PiAft Rtunilnt-ons for shipbuilding j'h:p-rcpia_vJiii! . A copy of the above draft Regulations has recently been sent to us by our Subsidiary Company, Koualls Insulation Co, Ltd. of Washington Station, Co. Durham, they being concerned with the references contained thoreln to asbestos^ since they carry on a substantial Insulation contracting buslnooc In connection with shipbuilding and ship-repairing. ' In addition, another Subsidiary Company of Turner A hvall Ltd- Is concerned, namoly J. W. Roberta Ltd* of Midland Works, Araley, Leeds, that Company being the owners of certain patents under which the iloberts Asbestos Spray Prose,** is operated! Kewalls Insulation-Co-. Ltd. hold a Liconaw from J. V/. Roberts Ltd. In respect of the us* cf that Process In connection with ship building and ship-repairing. The draft Regulations suggest that statements should be seat to the Ministry, Indicating briefly and provisionally what points on the draft Regulations It Is declred to discuss, and accordingly I have beon ackod to put the following points forward for consideration by the Department And for later discussion* 1* it may first be of advantage to refer to the circular letter sent out by the Ministry In August 1945 under the 2 heeding of MAsbestos Insulation aboard hipr` , to which in fact a lengthy reply was sent to the Chief inspector of P'a<;tori**c by 'Turner & liowall Ltd, on 4th October 1945- u*fc reply showt-d Winter alia) that no difficulty arose so far ui we wars concerned in the case of the six point:} nentlonel in thu circular letter or August 1545* oxsopt point 3 oon-jorning the use of respirators. As regards that point, our reply Indicated that the surras Cion that workmen engaged in fitting or removing any dry insulation material containing asbestos on board ship {as suggested in paint 3 of the circular letter* was in our view quite unnecessary and Inappropriate, and that if any such action were imposed In that manner it would mean in effect a very wide extension to the /isbostosir. Regulations, as the latter ha%e always applied in gtnsrol to manufaa Curing processes only and have not in any way applied to finished goods. Horovra our reply stated that It was significant that our experience in the past had shewn that no cases of asbestosls have arisen amongst employes* handling and applying finished products* that, X understand, i# still the aace. We are concerned only with those portions of the draft Regulations which apply to the use or application of asbestos, naaely the definition of asbestos in Regulation 3 and the provisions of Regulations 70 and 71 as to the use of respirators and the employment of young persons. The definition of asbestos in Regulation 3 states that asbestos means "any fibrour silicate mineral and any admixture containing any such mineral", and vo would like to ( : C> p be allowed to submit that such definition is certainly ambiguous and might be read as having an extreaely wide application.. For the reasons mentioned in our letter of 4th October 1945 and referred to also in this letter, we fee' that the definition of asbestos should be limited to the use and application of the fibre Itself (or any admixture thereof) in Its raw and dry unmanufactured state, and that to prevent aisunder3tending the definition should show that manufactured goods aro completely excluded from the definition. We feel It likely that It was not the Department' s Intention that manufactured goods should fall within the definition, but we think that the position should be made clear. Kewaixs Insulation Co. Ltd* (In addition to operating the Spray Process) apply on board ship a large range of manufactured insulating materials such as flections and fllgbs composed of magnesia and/or asbestos; In many cases these .- * < insulation products ore covered in cotton canvas or scrim cloth. In others they are mixed with cement, and in all these oases there In no asbestos dust and no possibility of risk* Moreover, a large proportion of the products applied by Newells insulation Co. Ltd. are what ore known as *65 Magnesia Products"f the asbestos content being the remaining 15 only. * As a basis for discussion we put forward for consideration by the Department the following revised definition - "Asbestos" means any magnesium silicate mineral in Its raw and dry unmanufactured state and any admixture i . -4 - containing any such mineral, this definition not Including therefore any manufactured products or plastic composed wholly or partly of asbestos*' S i i 3* As regards Regulation 70 dealing with respirators, the wording of paragraph (a) would te, In our view, mush too wide unless the definition of asbestos Is limited so as to exclude manufactured products. * * ` We are under the Impression that In general the references to asbestos Included In the draft Regulations have been Included because of the wide-spread use of the Asbestos Spray Process aboard ship, and that such references are therefore Intended tc be directed mainly to the use of that Process. Mo suggestion has ever been made to us before that respirators should bo worn In connection with tho handling or application of the finished artlcle&f on that basis every plumber for instance installing Magnesia Insulation Sections anywhere in this country should wear a respirator] ii . Before the Asbostosls Regulations came into effect In 1?31, we were similarly given the opportunity of making representations to the Home Office. as regards the wording thereof, and certain suggestions we then made were eeeepted having the effect of excluding all mauufaotured product- from the operation of thoso Regulations, and confining tho latter in effect to asbestos fibre In its dry and unmanufactured state. the Incidence of asbestosla since 1931 shows that such limitation of the Regulations was perfectly appropriate, as asbestosls oases within this organisation sln:e 1931 hav# .'siiLvr e j )< a In 5- - in general occurred amongst employees handling dry asbestos fibre as such and not annngst employees handling finished , goods made wholly or partly of asbestos. 4. As regards the Spray Process Itself, our spray operators have been provided with respirators for a number of years at the request of tho Department, and I am inforead that It is still a fact that no asbastosia cases have occurred amongst them, although the Process has been in use extensively for soaa 20 years and has boon operated to an increasing extent, particularly during and since the War- The Spray Troesss has been very significantly improved during the last fow years through the invention (patented by J W, Heberts Ltd.) of what Is known as the "Drum Damping Process* whereby the asbestos fibre is damped In a drum before the mixture is placed in the Huberts Spray Machine* This Invention has reduced the dust in the atmosphere to substantially that the Spray Process eon for Instance now be operated by J. V. Roberts Ltd. in railway carriage works alongside newly painted railway coaches whose paint Is still sticky* This point is mentioned in relation to the word . "vicinity* in paragraph (e) cf draft Regulation 70. That yord is not defined in tho Regulations and we Would like to submit that the phrase "immediate vicinity" should be used* Whatever risk there may be from the 3pray Process can dearly only exist (if at all) in the immsdlat* vicinity of the work. From the experience gained by J. W. Roberts Ltd. and Hevalla I ftii -6 Insulation Co. Ltd. uvor a lengthy period* the risk vould certainly apposr to bo slight, If not negligible, and this opinion is supported by the complete absence of any asbestoses :ases amongst the hundreds of spray operatives uho have keen concerned* lr. 'ast our lottor of 4th October 194? mentioned abov** is not available to youf 1 enclose a copy of it herewith* We would be glad to accept the Invitation contained in the Irefacc to the draft Regulations os to discussing the position personally with representatives of the Department at any mutually convenient data. . lours faithfully, for TtflWEft A DinALL LIMITED, -**' Secretary*