Document v13mDGGgDkV0aDRvbbZ8N7nw

jy,c.Cb>^r*l *97^ January 7, 1972 39UOSOCC National Institute for Occupational Safety and. Zj O CO --O- u"Jlj r i, r fj <5: C' o -- W. Clark Cooper, M.D. Professor In keslder.ee University of California School f Public Health Berkeley t California 93201 Dear Dr. Cooper: !i2 *ipw i T i; LU " h- h OO Inclosed for your review Is the draft doeueent "Criteria for a Bsccsaended Standard for Asbestos/* vfcich vo premised in our previous saetlcg Is Boclrville. The recccsesdatisms In the criteria doctsenr are the results of previous rectings with consultants, review by In-house KIOSK staff and discussion' with various people throughout the United States. tfe would not only .like to have your written cossents concerning the do curant. but would like ycur answers ts the follow!eg questions related to the development of the final criteria document. 1. What are the cpldeelologle studies or case resorts which Indicate that the esergency Unit of i flbers/cc(TA) should be lowered. Ad If e , to what nueber? In answering this' question, please note that several safety factors say be. Inherent In the emergency standard: s. The celling Unit of 10 flbers/ee will harre the affect of reducing the TUA in cany industries by shout 5CE (referenca Dr. Cooper, page UI-19). | BB 0021767 |j -------------- b. Procedural standards already Is the esergency standard, sd new work practices whlth will be adopted In Industries where these have been developed jointly by aarageseat sod labor, will have che effect of lowering sodo TWA exrosures below 2 flbers/cc. . c. Industrial hygiene engineering controls designed to achieve 5 flbers/cc will result In s lower T-CA concentration, l.e.. 3 or 4 flbers/cc. this document was not'a record of PPG INDUSTRIES, INC. DID NOT COME FROM |T'S FILES AND CANNOT BE AUTHEN1ICA i ED $Y PPG INDUSTRIES, INC. .. t \* -M9- fZ t-- * Page 2 - Dr. Clark Cooper % 2. Please ledleace your best Judgment regardIns feasibility In terms of years of achieving a 2 fibers/cc and a 5 fibers/ce(TWA) Halt In the following Industries: * a. Mining and milling b. Asbestos textile c. Manufacture of asbestos cement pipe and other asbestos products d. Industrial insulation (application) e. Marine Insulation (application) 3* Since cplddiologlc studies and/or case reports Indicate that crocldollte and armsite ray be core hazardous than chtysotlle and anthophyllite, should there be lever Hales for crocldollte and anosltc? It sh uld be noted that an analytic counting technique Is not really necessary. The lower lirIt could apply whenever crocldollte and acosite are used in any percentage. 4. Vhat are the next two significant Halts lover than 5 fibers/cc(TVA) ? Please take Into account differences in significant nuebers *'nr* eat leated B rellablHty of counting techniques. OO 5. Is there any evidence to Indicate that a lover licit is needed to pr tect against cesothcHoca than against fibrosis? According to Stewart, there eust be enough exposure to produce asbestosis before excess of bronchogenic cancer Is produced. Others (Knox, Hevkouac, and McDonald) have ranked exposures to asbestos productive of asbestosls `and noted an excess of bronchogenic carcinoma only in most heavily exposed groups. : t 6. Should a tine-weighted average exposure licit be the basis of the standard or could it be replaced by a dally average exposure? A J BB**00 21768*7 proposal to use a dally average irrplles sampling for a total 8-hour "j;---------------____?__1 workday or at least a major proportion of that Hco without the necessity of calculation,of a tixe-veighted average .exposure and determination of tine sequences necessary for the developncnt of a tine-weighted average exposure. This would undoubtedly necessitate longer sampling and consideration must be given to the ablHty of the labor Department Compliance Officers to speed that each tine In sample collection. If you feel that s dally average would be appropriate, pleaee Indicate vhat documentation la available In the Hterature that would relate a dally average exposure to a tlce-velghted average exposure standard. 7. Consideration of terminology used for labeling. Terminology used In the asbestos document Is essentially that which has been developed and used as basic criteria by the Manufacturing Chemists' Association la their Culde to Precautionary Labeling of Hazardous Chemicals. This labeling requirement seers to be primarily designed for ac*.tte exposure **ther than longer term chronic effects. There has been particular n nnriikiiFMT WAS NOT A RECORD OF ov ppfi INDUSTRIES, INC. __________ ' - 426Q ______________________ Page 3 - Dr. Clark Cooper opp iltlon eo use of che tern "fecal" In Che Ceres of asbestos exposure. Consent* should be cade relative to a substitute for this deaiznation if you feel It Is desirable. The info matloo included In Section V Includes that type of raterlal that vculd be incorporated for Infomatlon to the employee'and on a naSerial safety data sheet. This sheet Is still belay prepared by H10SH ar.d UCL, and It will be sceetlse before the data sheet has gevaraeene approval. 1 vould at this tire, however, like your cements on emergency trcacnect, and signs aad syaptoas of Intoxication that should be Included Is the criteria document. C-'j ': iT''' O 8. ACGXE has utilized s 30-year work span as being the normal work cycle f r the Aacrlcaa esployee as coopered to the 50-year work cycle used by the British and the 4C-year work cycle proposed by McDonald for his work la the Canadian Mines. The Act nose specifically requires chat the criteria developed, and the standard utilised in the United States, should cake the assumption that the worker will be mployed his full work llfeclne aad will be exposed for that period of tine to any given tutorial (Section 6-b-5). Do you feel that the 30-year work period La a legitimate tieu span for utilisation or should v consider a longer work lifetime for the American cxoleryee? This has obvious implications when a total work exposure approach la utilized such as the hundred flber/cc work year utilized by the British. co rr; dm ."* ** c3 LU ^ |siw oo 9. Under some elreucstsnees, such.as emergency or occasional short exposure periods higher than the standard, should It be necessary for Industry to apply for a variance for the use of respirators aad protective dothing! If not, under vest circumstances would you allow the use of respirators for exposure sbove the standard end for what tIre perloda? Please note that the British hsve an asbestos Halt of 2 (or 4) __ flbers/ec. yet do not require respirators until the concentration exceeds 12 flbers/cc If a delayed standard la adopted, l.e., going down fron 5 to .2 flbers/ec over a "reasonable" period of else, over what environmental level should re-pirator* be required, and how long can a worker be expected to have to rely on respirator protection? For example, the British have an envlrotaencal lisle of 2 flbers/ec but only require respirators above 12 fibers/cc. Z vould appreciate your coosenta by January 12, 1972. . Sincerely yours. THIS DOCUMENT WAS NOT. A RECton .neV Inclosure Charles H. Powell, Sc.B. Assistant Director, SIC*? Research, and Standard Development 4 $ c SUMiABY OF DR. COOPER'S RESPONSES TO OCSTCGKS AND COMMENTS r : X* Sparse. Refs. 55 & 58 end unpublished work from Pennsylvania ell lndlcateEneed for 2-5 flbers/ce. 2. Industrial Insulation: 2 fibars/ec, 2 jrr. Marine insulation sore difficult. 3. Veak; separate Units not indicated. 4. . Unsure. -Suggest 2 and 0.3 fibers/cc. 5. No good epideaiologic evidence but clinical data suggests need for lower Unit to protect against sesotheliosa. * 6. Time-weighted average preferable. 7. ---------------------- 8. 30 years not long enough; AO years store realistic; a few work 45-50 yrs. 4* * 9a. .Variances not needed for short exposures but use respirators. 9b. Begin respiration protection at 10 flbers/oc (celling). Kecomended Standards ivaraga of 2 to 5 f/ec probably-necessary to prevent asbestosls; -------------- possibility of cancer nates it prudent to adopt the lower figure. : u* C "i QO .* \^ j. THIS DOCUMENT WAS NOT A RECORD OF PPG INDUSTRIES, INC. DID NOT COME FROM IT'S FILES AND CANNOT BE AUTHENTICATED BY PPG INDUSTRIES, INC. 4262 k L f