Document v6qyq71mVmX9m8JjgYR7rkMpq

FILE NAME: Raybestos-Manhattan (RBM) DATE: 1972 Feb 25 DOC#: RBM041 DOCUMENT DESCRIPTION: Unpublished Report by Dr. Goodman Calling Industry to Account for Unsafe Work Conditions Art U # JOSEPH L. GOODMAN. M. D. 623 OHEAR AVENUE NORTH CHARLESTON. S. C. 29406 F e b r u a r y 25, 1972 Prepared by^Joseph L . Goodm an, M . D . Q ualifications: A ssociate P rofessor of Preventive M edicine, M edical U niversity of South C aro lin a Fellow Industrial M edical A ssociation M em ber Industrial Hygiene A ssociation of A m erica B oard Q u alified in O ccu pation al M edicine M e d ica l M em ber of B oard to C o m m issio n e r of L ab o r, State of South C arolina M edical D irector of R esearch Raybestos-M anhattan, Inc. G e n e r a l P r a c t ic e of M e d ic in e - 20 y e a r s XJ ~ " O ' - P L A IN T IF F S EXHIBIT (a.?r I have today after m uch thought and reading prepared this paper w hich presents som e of the facts about the asbestos industry and its relatio n sh ip to e ffe cts on the environm ent. A few w eeks ago, I v isited a u n iv ersity in the m idw est and in the la b o ra to ry o f a graduate student, 1 spotted an im pertinent sign which pretty w ell sum m arized the present state of those entrusted by industry to abate its e ffects on the environ m en t. The little sign read as fo llo w s: "W hen y o u 're up to your w aist in a llig a to r s , it 's d iffic u lt to re m e m b e r your o r ig in a l o b jectiv e w as to drain the swamp " . When it :s your jo b to help industry get in tune w ith the environm ent, you end up being assaulted from a ll sid es. A m erican industry has accepted the challenge to reduce its p ollution al load as rapidly as is econ om ically p ra ctica l and tech n ologically fe a s ib le . Industry is one of the m ost fle x ib le en tities in our so cie ty . Society supplies its cap ital, w orkforce; society purchases its products; in d u stry has to be resp o n siv e to s o c ie ty in o r d e r to e x is t. In d u stry h a s, th e refo re , learn ed to play the gam e acco rd in g to the ru le s w hich < 2 are set'out by so cie ty . When the rules are changed, industry m ust and w ill ad ju st to that ch an ge. C o n trary to m ost p resen tatio n s, I w ill begin with m y conclusions and c ritic is m s and subsequently to this w ill present the reasons for m y conclusions and c ritic ism s. There are six im portant factors from a b ir d 's eye* view o f what I c a ll the "sw am p " - the e n viron m en tal problem . They are as follow s: E pidem io logical studies are needed to esta b lish validity of the threshold lim it value concept. A ccord ing to the industrial hygiene new s re p o rt, the p ast fa ilu r e s on the p a rt o f in d u stry to conduct these studies in su fficien t depth and m agnitude is-probably responsible fo r the vulnerable position in which industry finds its e lf today. In attem p tin g to m eet the ch allen ge fro m those who c la im w id esp read unsafe w ork conditions throughout the A m erican industry, the asbestos industry, including R aybestos-M anhattan, In c ., and Joh n s-M an ville C o r p ., with the cooperation of the U . S. P u b lic H ealth S e rv ice did an 8 to 9 year epidem iological study and environm ental studies of the w ork site of the asbestos textile em ployee. This study was done with great expense to the industry with the com plete coop eration fro m the industry to this governm ent agency. The study consisted of a chest x -r a y , lung function studies, physical exam ination, and environm ental evaluation o f dust e xp o su re , and up to the p re se n t date th is 'study h as not been com pletely published. Although the study itse lf at the plants has been finished for quite some tim e, the results are not forthcom ing. It is m y under standing that the resu lts of the x -r a y s of our em ployees have not been com pleted because of the la ck of diligence of one or two of the rad io lo g ists who are assign ed to read the x -r a y s and com e up with their d iagnoses. It, th erefo re, appears to m e that one o f the m ost essen tial ingredients to the establishm ent of a true T L V lie s in this study which encom passes actual work place and a truly objective study done by an agency other than industry. T his study has been entirely neglected in a sce rta in in g fro m a com plete study the re su lts n e c e s s a ry to d eterm ine a T L V , and I cannot understand the haste in not w aiting fo r the resu lts of this p articular study. T here is a joint resp o n sib ility o f the re se a rch to xico lo g ists w ork ing w ith an im als in the la b o ra to ry and the occupational p h y sician s in in d u strial hygiene w orking with an actu al population in the fa cto rie s and other p la ce s. T h is would dem onstrate beyond a shadow of a doubt w hether the populations exposed to the toxic substances are kept below the established T L V w here there is in fa ct a m ethod to p red ict the p o ssib le ill health that com es fro m this exp osure. I do not believe that there are any studies at the p resen t tim e w hich provide valid in form atio n fro m w hich to a lte r the base T L V . T h ere are no lung or ab n orm alities which are p ecu liar to and solely related to asb estos in sin gu lar stud ies. The m any studies which are p resented show the abnor m a litie s to o ccu r with p erso n s who have not had any exp osure to a s b e s to s . In o rd e r to d erive a T L V it would seem to m e that one would need a fig u re w hich would apply to the w orking population exposed to this asb esto s that would indicate a lev e l from which an acceptable amount o f asb estosis would occur during a w orking life tim e . In^January, 1963, we entered into a cooperative study with D r . Lew is C r a lle y and D r , M a r c u s K e y o f the U . S . P u b lic H e a lth S e r v ic e and did m fa c t, begin this study w hich related to the w o rk ers' sm oking habits, related to the w o rk e rs' health h isto ry , and to the w o rk e rs' environm ent. The study was com pleted but the resu lts are not forthcom ing, and I do not 4 -understand the urgency in estab lish in g a perm anent T L V before the com pleteness of this p articular study is presented and criticize d . Iso lated reports are of no value in the establishm ent of a T L V because as I have stated' b efo re, the findings in iso lated rep orts -o ccur in people who do not have any contact in asb esto s o r asb esto s related industries. The only published epidem iological study that is in existence -today and which the N IO SH A has used as a crite rio n fo r establishing the low er T L V fo r asbestos is the B ritish study. I am sure that you have gone over this m any, many tim es, and there are many criticism s o f th is rep ort as it is a v e ry lim ite d am ount, a p p ro xim ately 290 m en, and there is some question about the re lia b ility of the dust counts. T h e re is con flictin g use o f both cro cid o lite and ch ry so tile in this m ill a.s we can a ll te ll that w ith cro cid o lite there is an in cre a se d fib r o s is , asb e sto sis, carcin o m a, and m esotheliom a. It is a known fact that this . * m ill w as e xceed in g ly dusty fro m 1920 to 1950, and that this T L V w hich is derived from the studies of the B ritish epidem iological study is re a lly a goal rather than a s tric t m easu re to go by. F r o m the B ritish study the em ergency five fiber standard was derived. The B ritish them sdves do not operate at a le v e l o f two fib e rs p er cc and con sid er it m o stly a s a goal rather than to indicate that it is a s tric t T L V to be enforced . T h is is evidenced by its notation that r e s p ir a to r s m ust be w orn when the fib e r coun t r e a c h e s 12 fib e r s p e r c c , and now 10 fib e r s p e r c c . T h ere is at the p resen t tim e an ongoing study in Can ada to indicate that the 7 fib ers per cc to m ost probably 5 fib e rs per cc is a safe le v e l -without fib ro sis or a sb e sto sis. It is also disappointing to me that a group such as the A C G IH , w hich review ed the in itial inform ation and cam e up with the suggestion 5 of a 5 fibers per cc as a threshold lim it value or em ergency standard was in essence supposed to review the current lite ra tu re again in the spring was not even consulted in the fin al production o f a T L V . This com m ittee was headed by D r. Stokin ger, who is one of the forem ost to xico lo g ists in the w orld today. T he A C G IH lis ts o f thresho ld lim it valu es that have u su ally been set a re not at le v e ls to produce a zero resp on se, but at le v e ls below w hich the response constitutes no threat to h e a lth . I do not understand why th is p a r tic u la r group w as b y p a sse d . A n o th er stan d ard in the T L V is b ased on the 50 y e a r w ork ing period as a life w orking tim e of an individual in the a sb e sto s-textile group. In research in g our em ploym ent status, we find it to be ap p ro xi m a te ly 30 to 35 y e a r s as a s a fe r le v e l and th at anybody in the a r e a o f 40 y e a r s o f w orking tim e is rath er' r a r e and o f su ch a s m a ll p e r c e n ta g e o f our w orking population to be s ig n ifica n t. Another factor is the consideration of a T L V for insulation w orkers as com pared to tex tile w o rk e rs. It is m y im p ressio n fro m the s ta tis tic s that are revealed in the insulation w o rkers by notable re se a rch e rs in the field that these people are exposed to very high dust le v e ls. One draws this conclusion fro m the fa ct that they have the highest in stan ces of asb estosis of any group of asbestos w o rk ers, and the highest instances o f carcin o m a both bronchogenic carcin o m a and the ra re m eso th elio m a. It appears to me that there is a double standard h ere, of w hich one value is being p laced fo r the tex tile w orker to function under and ab solu tely no m onitoring to be done on the insulation w orker at the w orksite. It is e n tire ly fe a sib le to m onitor the in su lation w orker at h is w o rk site . U su a lly the dustier the w ork p lace, the shorter the tim e o f m onitoring. A one hour cycle could be easily accom plished by a lap el device for m easu rin g dust. A s I said , the dustier it is the sh orter one has to ' -X > 6 place the individual m onitoring device on the w orker. Because of the lack of controlling devices on the insulation w orker, and the numerous other exp osures that these people have fro m going fro m one jo b to another, it would seem that a greater and clo se r m onitoring of the insulation w orker would be indicated. The riext c r itic is m is the econom ic facto r and the econom ic im pact on the industry. T he asbestos textile industry has actively been pursuing the goal o f control o f asbestos em issio n s using the best available technology of the tim e s. Everyone agrees that the naturally occu rrin g fib ers c la s s i fied as asbestos a re indispensable in our m odern technological society. A sbestos has m any u ses, provides protection against fire , and d ete rio ra tion in scores of products in our daily use. It saves countless lives and billions of dollars in property dam age. It is used in schools, houses, theatres, o ffices, and other public buildings, ships, sp acecraft, brakes' on autom obiles, tru ck s, busses, and tra in s. A ll are dependent upon asbestos as a vital component of safety through their brake linings. It is estim ated that it adds to the nation's econom y to the extent o f two b illio n d o lla r s and does in volve the liv e lih o o d o f p erh ap s 200, 000 wage earners and their fa m ilie s . The econom ic contribution of the asb es tos industry to the nation's econom y, th erefo re, is substantial, outside of playing the variou s life saving ro les in our society* To quote the N ational A cadem y o f S cie n ce s, "A sb e sto s is too im portant in our econom y and technology fo r its essen tial use to be stopped". T h erefo re, if one p laces an u n realistic T L V , it would p lace an econom ic burden on the industry which would result in annihilation. It is obvious from the trend o f the industry that such things are alread y beginning to take 1 p la ce . There is now a plant in the p ro ce ss of com pletion in M exico / 7 T here would be a rapid and la rg e in flu x o f Ja p a n ese m a te ria ls without any environm ental encum brances. Som e com panies have sought to decrease their production of certain products by elim ination from 30 p h a se s down to 9 p h a se s w hich r e s u lte d in a c o rr e sp o n d in g d e c r e a s e in one p la n t'fr o m 250 p eople to 75 p e o p le . O ne com pan y h a s s o ld a com plete plant because of the d ifficu ly in environm ental co n tro ls. A nother im portan t point that I think is m o st p ertin en t to the establishm ent of a re a listic threshold lim it value, as we are using b a sica lly the B ritish study as a b asis fo r our threshold lim it value, is that the B ritish econom y is certain ly different than o u rs, and that we would then expect an influx of B ritish products and Jap an ese products with w hich our industry could not com pete. It seem s to me that this would be a severe econom ic im p act, w hich would req u ire the re-lo catio n of m achinery, and in som e in stan ces, actually the total rebuilding of the m achinery and perhaps the building of en tirely new p la n ts. The w alls of som e fa cto rie s and the construction would have to undergo extensive alteratio n s. I doubt if the engineering ability e x ists at the present tim e without a great deal o f fin an cial outlay and tech n ical know-how to accom plish the 5 fib e rs p resen tly set in the em ergency standard. In some areas, we already are at 5 fibers.an d even 2 fibers or le ss, and are constantly trying to achieve low er dust le v e ls . We have been w o rk in g on th is p ro b le m sin ce 1937 and h ave a c c o m p lis h e d a g r e a t d e a l. I understand from com petent authorities that it m ay even take 2 years to get to the 5 fib e rs , and the fe a sib ility of getting to 2 fib e rs seem s im possible as one company put it, annihilation. M y conclusion fro m the econom ic im pact would be to con sid er the question as to w hether 2 is s a fe o r 5 is s a fe . We re a liz e , o f co u rse , th a t 12 Is too h ig h , so m e w h e re betw een 5 and 7 a p p e a r s to be a s a fe le v e l that, w ould give us the low est am ount o f a s b e s to s is , p erh ap s lo w er than the B r itis h a re able to a c c o m p lis h w ith th e ir so c a lle d 2 fibers per cc. . A t this point, I would lik e to introduce a study that we have done S at our plant and we w ill in se rt at this p a rticu la r tim e the studies that are done re la tiv e to the relation sh ip o f dust, tim e exp osu re, and pneum oconiosis at our plant. It seem s im possib le and creates a great danger to our so ciety if we are drawn into this feelin g o f fa ls e se c u rity . T h ere is no data of w hich I am aw are w hich w ill answ er the question of what atm o sp h eric le v e l should be se le cted as a stand ard. The m o rtality death is a v ailab le, but environm ental data is not a v a ila b le . In e sse n ce , the m e d ica l au th o rities are confronted w ith the p ro b lem of selectin g an atm osp h eric concentration num ber without benefit of an exposure response or definite inform atio n as to the environm ental con d i tion w hich appeared to have resu lted in these se le ctio n s. T h ere seem s to be som e confusion am ong som e of the au th orities w hose judgm ent has been used in the estab lish m en t of the em ergen cy T L V as to what the c o n d itio n s w e re 20 to 30 y e a r s a g o . W e h a v e d u st co u n ts a v a ila b le in the 1930's to show the dust counts exceed ed in som e c a s e s between 30 to 50 m illio n p a r ts p e r c u b ic fe e t . In 1935, it r e m a in e d the s a m e , but in 1937 w ith the in sta lla tio n of the flow o f a ir into a c o lle c tin g sy ste m , there w as a rem arkab le drop in the dust o f the tex tile plant. The drop w as so m uch that in the 1940 e ra we ap p ro ach ed a p p ro x im a te ly a 5 m illio n count in the spinning and w eaving a re a s w ith a 2 m illio n p a rts per cubic feet of a ir in the card in g a r e a . A s we have only re ce n tly begun counting the fib e rs p er c c , it is d ifficu lt to relate 9 these two. W e fe e l th at n othin g h a s ch an ged a p p r e c ia b ly in the la s t 20 y e a r s to m a k e u s fe e l th a t w e h a v e in c r e a s e d in ou r d u s t in e s s , "but w ith the w etting down of v ario u s p roced u res and the yacuum ing p ro ce d u re s, that our dust counts have b e co m e rem ark ed ly lo w e r. I do not a g ree w ith the p a p e r p ub lish ed by W illia m s , et a l, that in 1930 in one o f h is p lan ts that he w as below 5 m illio n p a rtic le s per cubic fo ot. I would im agin e th at th e r e is a z e r o m is s in g and it sh o u ld be m o r e lik e 50 m illio n p a r t i c le s , o r so m e w h e re betw een 30 and 50 m illio n p a r t ic le s p e r cu b ic foot. I f you could get below 2 m illio n p a rtic le s per cubic foot Considering a ll >the equ ip m en t w e h a v e in o u r p la n t it w ould be m o s t u n u s u a l. We a g re e that the asb esto s dust should be stre n u o u sly c o n tro lle d , and it is strenuously con trolled in our w orking environm ent in ord er to prevent asbestosis. In the c r ite r ia docum ent there is a re fe re n ce to the fib e r count dependability. In those that w ere received at our fa cto ry , these w ere prom ptly rechecked and the relation sh ip w as shown that the co n sisten cy existed in our m ethod of fib e r counting so that we w ere consistent throughout. The fib er counts in the areas w hich w ere dusty rem ained the sam e and w ere consid erably low er than those done by the U SP H S. We a lso c r itic iz e d the low er dust counts w hich we knew should be h igh er and these w ere repeated and found to be con sisten t w ith our p revious dust counts over the m any y e a rs in these p a rticu la r a re a s . The point that I am tryin g to m ake is that we are often v e r y c r itic a l o f our counts and are repeating dust counts constantly to in sure their re lia b ility . E ven by our own dust counting experts there is a 10% to 15% e r r o r in co u n ts done by h im . A n o c c a s io n a l du st co u n tin g on an o cca sio n a l v isit to a plant by an agency lead s them to b eliev e, ------^ ------ th at t h e ir co u n ts a r e v a lid . T h e r e fo r e , w e 10 le e 1 that on the b asis o f the co n sisten cy o f our counting that we w ould p lace m ore credance in a co n sisten t report of both the higher le v e ls and the low er le v e ls rem aining the sam e done by our en gin eers. T h is p a rticu la r d iscrep an cy o f the U SP H S h igh er counts, being too -h igh , and the low er counts, being too low , w as pointed out to them .not to be e s p e c ia lly c r itic a l of them , but to point out that there m ust be a m arked difference in the re lia b ility of their (USPHS) coun tin gs, and that we are as constantly c ritic a l of our own counts Ju s t as we are of theirs (USPHS). T h e r e is a decided d ifferen ce in the approach to counting if one u ses the B ritish standard of the sam pling device that was used and co n trasted with the p erso n al sam p ler on w hich our p resen t standard is s e t . W e fin d o u tsid e o f the 10 to 15% s e t d iffe r e n c e s th a t one m a k e s in p erson al counts that th e r e is a decided d ifference in the reduction in the B ritish count as com pared to the A m e ric a n count. T h e B ritis h ten d en cy is to u n d e re stim a te the am ount o f fib e r s p e r c c and to som e a u t h o r it ie s , it ru n s a s h ig h a s a p p r o x im a te ly 15 to 25%. I t , t h e r e fo re , a rr iv e s at a low er standard than would have been the situation .had they had a p e rso n a l s a m p le . T h is w ould in c r e a s e th e ir stand ard to .a p p ro x im a te ly 4 fib e r s p e r c c , had it been d e riv e d on a 50 y e a r w orking place exposure. 1 have le ft the la st point of carcin o gen es as the la s t fa cto r, because it is com m on know ledge that asbestos is con sid ered a co -fa cto r in the production of bronchogenic carcin o m a and the developm ent o f m eso th elio m a. M any authorities have docum ented the establishm ent of tra ce m etals being resp on sible fo r bronchogenic ca rcin o m a , others have v ery definitely tied in sm oking d ire ctly with bronchogenic carcin o m a, but the problem s till rem ain s unsolved. 11 /The p ro b le m o f m e so th e lio m a in the a s b e s to s te x tile in d u stry in tr ig u e s m e in that I h ave se a rc h e d d ilig e n tly throu gh 51 y e a r s o f re co rd at our plant and find 2 ca se s, one of w hich there w as no autopsy 'done and th ere w as a c lin ic a l d ia g n o sis o f m e s o th e lio m a w ith m e ta s ta s e s through a ll p arts o f the body. The fir s t case rev ealed no a sb e sto sis in the previous x -ra y s of this patient. The second case was a m esotheliom a -of the abdom en, autopsied with m etastases to the lungs and p leu ra. P a th o lo g ica l exam ination of the lungs revealed no asb esto sis present ^although th is em p lo y ee had been exp o sed fo r 17 y e a r s . 1 w ould a s s u m e th at in 51 y e a r s o f exp o su re to a s b e s to s and esp ecia lly since in the e arly years here we used cro cid o lite in our >/ p ro d u c t, th at.o n e w ould se e am en o rm o u s am ount o f m e s o th e lio m a o v e r th is length of tim e . To have two questionable m eso th elio m as, one undiagnosed., the second, an abdom inal m e so th elio m a, w hich is co n sisten t -with w hat m igh t o c c u r in the g e n e r a l p op u lation is r e m a r k a b le . I h ave a ls o re v ie w e d 19 c a s e s o f m e s o th e lio m a at our M e d ic a l U n iversity and find that there is no occupational connection between the 19 that are lis te d in the pathology departm ent of autopsied p a tie n ts. T h ere is no occupational h istory in related in d u stries from w hich even a tra ce of asbestos could have been acq u ired . In none of the autopsied Teports are there lung sections showing any asb e sto sis p resen t in the t is s u e . It is m y opinion that a standard relatin g to the m eso th elio m a is im p o ssib le to d e rive . The co-carcin ogen ic aspect of bronchogenic carcinom a m ust -strongly be considered, but a standard cannot be derived as to broncho- -gen ic ca rcin o m a . T h is then leaves us w ith the sc ie n tific deduction fo r the reduction of asb estosis in the industry. I believe that a standard s t r ic t ly e n fo rce d o f 5 fib e r s p e r c c to a lim it o f 10 fib e r s p e r c c a t w hich i- S 12 tim e one should w ear a re sp ira to r with a m argin of about 7 as the safe le v e l, perhaps a level o f from 5 to 7 b ein g re a listic fro m a health standard. I would anticipate a rem arkable drop in the a sb e sto sis, and p erh aps even below the B ritis h 1%. There are other variables that one co n sid ers, the personal susceptability of the individual, the fact that he sm okes, and his other related m edical h isto ry has a great deal to do with his su s ceptability to a sb e sto sis. I believe strongly that on the present scien tific data that is av ailab le that it would be u n re a listic to set a standard below 5 fib e rs per c c . I believe that the.standard should be from 5 to 7 fib ers in which the industry could operate with the greatest m edical e fficien cy and safety. Although to accom plish the 5 fib e rs would be a great econom ic im pact on the industry, it could be obtained in a m atter o f 2 y e a rs . 1 do not envy the in d ivid u al who has the re s p o n s ib ility o f se ttin g th is stand ard, but as a p h y sicia n o f som e 20 y e a r s ' e x p e rie n c e , I . cannot help but fe e l that resp o n sib lity goes w ith m atu rity and judgm ent. Honest com m ents made in the atm osphere of com passion fo r fellow w orkers in the asbestos industry and the p roblem s of industry its e lf should not be taken lig h tly . 1 hope this b rief sum m ary of the asbestos heaLth problem has been o f in terest to you and this additional inform ation w ill be a reso u rce to select a re a lis tic T L V fo r the benefit of a ll concerned.