Document vBGZErv0Zbb5zpam35vp8NLow

-v GRACE Construction Product* Division TO FROM DATE P. E. Korenberg J. C. Hortenstine June 11, 1990 cc: J. J. Adams B. C. Rugg You may have seen this package from American Energy Products which refutes the MMMF study from IRAC. We may want to provide some answers. We have already replied to the E-136 argument. _ J. C. Hortenstine /Pf Attachment \ r l5l92807 CORPORATE HEADQUARTERS jSNSMrmt.American Energy Products 5 EAST GARVEY (NORTH) SUITE 101 COVINA, CA 91724 (818) 915-1428 FAX (818) 331-2587 Western 300 East 600 South Provo. Utah 84601 Plant (801) 377-1122 FAX (801) 377-1127 Eastern 17B Marten Drive South Gold Industrial Parh-Robbinsville. New Jersey 08691 Plant (609) 890-0033 FAX (609) 890-8599 Southern 6717 Polk No. B Houston, Texas 77011 Plant (713) 923-4933 FAX (713) 923-4934 May 4, 1990 Ms. Lisa Vandeman Vastale, Loftus and Kalista 1140 C West Pioneer Parkway Arlingotn, Texas 76013 Re: North Halthom Road Elementary School RECEIVED MAY 0 7 1990 vlk architects, inc. Dear Ms. Vandeman: This is following to our conversation today, regarding the specifications for the above referenced project. Our understanding is that publicly funded projects must be open for bidding for all products that meet the pertinant specifications. Naming a single product is not open bidding. On the contrary, it appears to us that this is a closed specification. You stated that the fireproofing must be listed in UL Design S701 in order to be used. The only products approved in Design S701 are W. R. Grace Products MK4, MK5, MK6, RG and RG1, for general concealed fireproofing. The enclosed information shows that MK4 and MK5 are contaminated with asbestos. RG and RG1 are used in asbestos abatement resprays. That leaves only MK6, which is manufactured exclusively by W.R.Grace and Co. Therefore, only one product is specified. You may also find it interesting that the enclosed information shows that MK6 and RG do not pass ASTM E136 non-combustibility test. The enclosed information regarding the requirements of SBCCI (Southern Building Code Congress International),&B0CA (Building Officials and Code Admini&rators International) may also be of interest to you. Also, GSA Masterspec requires that both sprayed fiber and cementitious fireproofing shall be non-combustible. SprayDon Fireproofing has been effectively used in many air plenums throughout the country. The following are just some of the jobs where SprayDon has been used in this situation: World Trade Center New York City, NY Buffalo General Hospital Buffalo, NY IBM Headquarters' Charleston, SC 15192808 Ms. Lisa Vandeman' - 2. - May 4, 1990 Marine Midland Bank Buffalo, NY New England Executive Plaza Burlington, MA Broadway Building. Los Angeles, CA Sears - West Town Boise, ID The enclosed ASTM E859 Air Erosion Test was made op unsealed SprayDon. The result is well below the 0.025 gr/ft2 dust accepted under this criteria. American Energy, however, requires that the SprayDon surface be tamped and oversprayed with SprayDon Sealer in air plenum areas. This is to ensure that any loose fibers that might have been deposited on the finished applicationby overspray, is well bonded and locked in place to the surface. Our UL Design S803 is comparable to Design S701. We appreciate your taking time to review the enclosed information and we hope you will include SprayDon as an approved product on the specification for the above referenced job. If you have any questions, or desire additional information, please let me know. Sincerely yours, AMERICAN ENERGY PRODUCTS CORPORATION Terry L. Wildeboer Manager TLW/s end: MK Packet cc: Hobson Harrell - AEP Esteban Torres - Congress of the US George White - Los Angeles Times 15192809 Hcllmulh, Obala & Kassnboum, P.C. Aj-chilocturc. Inlorlors. Planning. Crnphlcs. Enslncorlng March 30, 1937 1110 Vermont Avenue. NY/. Sullo 330. Washington. D.C. 20005 Telephone: 202 <57 tMOO Mr. Jose Lora Homart Development Co. 55 W. Monroe Street Suite 3100 - Xerox Center Chicago, IL 60603 Re: Tysons II Retail Center Fireproofing HOK File No. 4232-711 Dear Jose: Please advise Gordon McLennan and the General Contractor for Hyman Construction Company that HOK will not approve W.P.. Grace's Monokote IV or Monohote V for fireproofinq for the Tvsons II Project.. The Specifications' list W.R. Grace as one( of the acceptable manufacturers for the specified fireproofing. However, we have recently learned that W.R. Grace's fireproofing products noted above contain-some amount of asbestos. Although the manufacturer claims that .the asbestos content is "very low" and within current allowable Government limits, we have had an established policy for some time of not specifying any product which contains aov asbestos whatsoever. Please provide us with a copy of any written instructions you issue to the parties involved in this matter. Sincerely yours, Donald O. Francke Construction Administration cc: Gordon McLennan Jim Hampel Scott Kirk Dick Sweeney Bob Barr 15192810 ^Covering Albemarlecharlattesyille and the. UntveiiH 1087 Chariottesvilla Obsover, Inc. 100 South Street West February 19-February 25, 197 Attorney Generals Office ignores oversight law byA.JL Pecalee Department Of General Services Boraas* reply raises the question: The Attorney General's office apj- and the court files of the Htigation is ; the Attorney- General's office bears to have ignored the Virginia which took, place." The- Attorney. . meeting Its responsibilities under the State Code in not Investigating possi General's office appeared to Virginia Antitrust Act and acting as ble rigging of bids on government disclaim any . responsibility or a defender of the U.Va. Hospital7 If services and goods used in the authority to deal witha possible case such is the answer, there may be a building the new U.Va. replacement of manipulation of bidding by a conflict of interest with the law en hospital. ; state agency (U.Va.). forcement arm of the state govern 1 The Observer wrote to Attorney ' In fact, the Virginia State Code ment protecting another state agen- ficheral Mat? '-SU<* Terry last Mot bnlysaywthai tiggipg -tUerih* or' *y against outside Ootnptainta/iil. December suggesting that the otherwise' manipulating bids for The question Of the safety of the University had accepted a bid for State government; agencies is new hospital's fireproofing was first fireproofing the new addition of the "unlawful," It says' that the At raisbd by the Observer in its July 17j U.Va. medical hospital that was not torney General "shall have concur 1986 edition. This' quoted only higher than others submitted, rent. power, and .authority to In Washington attorney David M.F; but would Use a fireproofing vestigate arid prosecute any Violation Lambert' as saving that/ using a material containing asbestos. The Of v Section 59.1-68.7 . (which ` pro fireproofing material containing letter asked if. any Virginia laws had hibits manipulating bids to statb asbestos will mean that in the future, been violated in the bidding process. ' ageriries). 'The code also authorizes, to : meet * Standards of the En A copy of the letter was sent to the Attorney. General to investigate vironmental..-Protection Agency Senator Thomas J. Michie Jr. and complaints about posable violations (EPA), the fireproofing (Monokote U.Va. officials involved in the bid of the Virginia Antitrust Aci. . MK-5, manufactured by ' W.R. ding process. Boraas* letter said that the infor Grace . Company).will have to be The reply to the Observer's letter mation requested by the Observer removed at great cost . from assistant Attorney General, .involved "legal advice to a state in MK-5, said Lambert, contains Russell L. Boraas, referred any stitution. Such advice' from an at minute quantities of asbestos. A questions to the University "its ar torney to a client is not normally Grace Company office later certified chitects and the Commonwealth's shared ydth other parties.'*. ass OVERSIGHT, paga 12 OVERSIGHT, from paga that the MK-5 would never exceed first bid on November 4,1985 which one percent. However, the Grace required "asbestos-free" fireproof .Company did not record that it ing. In a revised bid specification on .would indemnify the University for January 22, 1986, the requirement any safety hazard or future rectifica for "asbestos-free1* was removed. tion of mistakes in using asbestos- During the - bidding : process, ining fireproofing. MK-5 Southeastern Shelter of Durham, meets current EPA standards.. ` N.C. had placed a bid for fireproof- . U.Va. changed its specifications . ing using asbestos-free materials and. for fireproofing materials from Its asking $150,000 less than the Once Company. The University said it refused.that bid because asbestosfree fireproofing does not adhere as well as one containing asbestos. An official of the Veterans Administra tion which had used this material told the Observer, however, that asbestos-free fireproofing is not only cheaper than the MK-5, but just aseflective if applied properly. HAZARDOUS BEDFELLOWS: The VERMICULITE_ ASBESTOS CONNECTION Since 1971, government and industry have known that, virtually all vermiculite produced in this country is ' contaminated with asbestos. Why don't the 4 million: people who live in homes insulated with vermiculite know this? EXPOSURE . Environmental Action Foundation 724 Dupont Cirde Building Washington DC 20036 J TA . By Dave 1'ontzer with Alice Cave t's a thoroughly modern product Ifor the lifestyle we've grown ac customed to. Vermiculite is light "In 1971, the producer of 80% of the weight and non-combustible. It's freeflowing and insoluble, chemically inert, resilient and non-abrasive. nation's vermiculite announced that virtually all of their ore was contami This impressive array of attributes enables vermiculite to insulate, nated with asbestos." fireproof, extend, lighten, and aerate products ranging from potting soil to concrete, plaster board to kitty litter. EPA Releases Documents Regulatory Options In our IrnsHngconsumer role we've scattered free-flowing vermiculite Through Freedom of Information requests Environmental Action Foun-. OSHA, under their broad mand.T to provide a safe environment f about our attic, and we've spread dation has been able to examine EPA vermiculite-lo.ided-fertilizer onto documents on asbestos contamina workers, has two regulatory optio with regards to vermiculite. The fir our lawns. Unfortunately, in our all too frequent uninformtti consumer role, we've handled vermiculite without knowing that it's contami nated with asbestos, a proven carci nogen. tion, of vermiculite. These reports date back to 1977. Although vermiculite has been mined in the United States since 1929, no studies on the health effects of exposure to the mineral have been is an exposure standard and t; second a labeling requiremer Theoretically, OSHA's current e posure standards protect worke evenafter the vermiculite has left t: processing plant. But as an EF Contamination Revealed located. The effects of exposure to asbestos, on the other hand, is well report notes, "Realistically, howeve it is difficult to imagine the standa The vermiculite/asbestos connec tion went public in 1971. That's when W.R. Grace and Co., the largest domestic supplier of vermicuIite, revealed the results of tests confirming asbestos contamination in the ore mined at their Libby; Montana site, producer of 80% of the nation's vermiculite ore. In 1976, both the. Occupational Safety and Health Administration documented. By 1918 there was enough evi dence on asbestos hazards to cause -American and Canadian insurance companies to stop selling life insur. ance to asbestos workers. The cancer-causing potential of asbestos was suspected as early as the 1930's, although the first standard for occupational exposure to asbestos wasn't set until 1971 by OSHA. being enforced at many of these lat sites. For example, it is doubtful th employers at greenhouses wlie vermiculite is used as a soil cor.c tioner run their businesses with !: asbestos standard in mind. Fe employers besides those involved the initial stages of vermicu' processing know that vermiculite often contaminated with asbestos .This is the case with many oth (OSHA) and the Mine Safety and Health Administration got involved when workers in the vermiculite industry came under regulatory "32 of the 221 vermiculite workers tested had lung disorders normally "protection" from asbestos dust. associated with asbestos exposure." ' Prior to this involvement vermiculite workers were exposed to asbestos dust concentrations as high as 245 One of the first reported incidences fibers per cubic centimeter (f/cm3). of asbestos-like health problems The new OSHA standard of 2 f/cm3 . appearing among vermiculite pork is even recognized as too high. ers was in 1978 by O.M. Scott and In 1979 the Consu'mer Product Sons Co., a manufacturer of agricul Safety Commission (CPSC) acknow tural chemicals. Workes at their. ledged the contamination problem Maryland fertilizer plant developed when they ordered a general study of -lung disorders normally associated the use of asbestos in consumer with, asbestos exposure. Of 221 products and included "potting tested, 32 had disorders ranging material" (vermiculite) among the from fibers in the lungs to bloody products to be tested. However, the pleural effusions, with symptoms scope of the study was later nar ranging from coughing, fatigue and rowed to include only products in rh-*~' p*:" *** which asbestos is intentionally added. The crucial point is that research on asbestos-caused cancer in labor industries using vermiculite as we including construction worker "drywall installers, brick and sto: masons,, plasterers, insulation wor ers, and anyone involved in comme grirvu"* - ----- Why are employers and employe largely unaware of vermiculite contamination with asbesto: OSliA's labeling regulations tt asbestos,"... all (asbestos-contai. ing) raw materials, mixtures, co; tainers ..." covers vermiculite, b- the regulation is self-service. Cor pliance is voluntary as long as " ..'. manufacturer believes that the u; atory animals has shown that there is (handling, storage, etc.) of a prodr Dave Pontzer, a recent graduate of no threshold level below which will not create fiber levels above t. Georgetown University, just com exposure causes no effect. Therefore, OSHA standard." Even, this is ult pleted an internship with the WaTS since no safe levels for atmospheric mately a moot point, since OSH Protect. Alice Cave is a researcher concentrations of asbestos exist, any stated in April of 1980 that th with an environmental consulting exposure will produce a percentage of exposure standard is insufficient t firm. _ cancers in those exposed. protect workers' health. i, 15192813 / ? yVsrmiculite next finds its way into ? . ` ;\e home, vyhere it is "regulated." by \CP'S. The.Federal Hazardous Sub< /stances Act gives CPSC the mandate ' / to regulate hazards presented by the /dl presence or use of toxic and other / ^hazardous substances in the home. .. 'Like OSHA. they have the authority to ban, regulate, or require labels on products. CPSC has already exercised this authority with respect to asbestos banning two consumer products containing asbestos fiber; artificial embers and spackling compound. Neither is associated with the ver- miculite industry. At that time CPSC went so far as to s.iy that there is no safe level of exposure to asbestos in consumer products, and that, "only banning these products can ade quately protect the public fro'm unreasonable risks of injury associ ated with them." As was mentioned earlier, CPSC began a study of asbestos in consumer products over three years ago, excluding products like vermiculite which contained asbestos as a contaminant. To date, nothing has been reported. CPSC also has the authority to require content labeling of products. In view of EPA reports concerning :the significant levels of consumer exposure to vermiculite, this action, at the very least, should have been taken some years ago. A study prepared for EPA by an independent Virginia-based consulting firm makes this quite clear. The report states that, "Over 74 million persons use lawn and garden fertilizers each year. If the fertilizer is vermiculite-based, estimated exposure levels to asbestos of 4.4 ug/m^" and 28 ug/m3 could This weight method of measuring . asbestos exposure (ug/m^-milligrams per cubic meter) contrasts with the earlier volume method (f/cmJ-fibers _ per cubic centimeter) in the same way ~ that a pound of eggs contrasts with a dozen eggs. Unfortunately, the Virgi nia study we refer to oniy used this weight method, and it's' virtually impossible for us to correlate the two different systems with the informa- tion we have on hand. Further, OSHA only uses the volume method in its asbestos standard. Suffice to ;ay, however, that as the general "rule of thumb" regarding asbestos,, there is no safe exposure level, indi cates these latter figures using the weight method are all to be consi dered extremely hazardous. result Irum lawn treatment jnu gardening, respectively." The report goes on to estimate that 188,000 people a year are exposed to levels of asbestos as high as 13,600 ug/m^ during the installation of vermiculite attic insulation. 4,230,000 people live in homes insulated with vermiculite. Additionally, there are at least 3,000 owners of hobby greenhouses whose exposure to vermiculite should be comparable to that of a greenhouse employee occupationally exposed. Anyone repotting their houseplant with potting soil contain ing vermiculite would be exposed to a small amount of asbestos fiber, as would people who handle kitty litter, barbecue base, or who put up their own drywall, plaster, etc. The consumer has no idea what's being handled. None of these pro ducts, from attic insulation to kitty litter islabeled.CPSC apparently not being sure how to proceed. After the' strong stand taken in respect to artificial embers and spackling com pound, i.e.. no safe'exposure level, this inaction is jnmmprphpnsiblp The EPA has done extensive research into the problems associ ated with asbestos contamination of vermiculite, [compiling a wealth of "information*6n the subject. As yet they've done nothing with it, issuing no regulations or warnings. It appears that since a safe lower limit for asbestos exposure cannot be found, the.problem is being covered up. How else can one explain that at least three government agencies have been studying a known toxic substance, occurring in the market place, for at least five years, and not .done so much as require that it be labeled. Another EPA report, also obtained through FOIA, frames the problem: . "Although the quantities of as bestos released during end-use of vermiculite are small in comparison to the mine and workplace, the aggregate risk to the consumer of product end user may be large in view of the large number of people exposed. Moreover, users may be particularly vulnerable and unpro tected due to ignorance of the potential hazard." Using vermiculite in an enclosed area, such as an attic, greatly increases the exposure level to asbestos fibers in the air. Ora garage. Or a basement. The point is clear, workers and consumers are being exposed to a known hazard without i i.c iniui .i.jiiun lu njnUle it sale.). to avoid it altogether. As the EF report points out, "There are ac quate substitutes for most of t uses of vermiculite. If vermicu! were not available, perlite, cellu: concrete and fiberglass would be t most common substitutes." There the matter now stands. T tragic consequences of asbest exposure are well establishedJVe i miculite Ts a known carrier I asbestos fibers.JThese microsco; 1 fibers are released into the atmc phere from the time vermiculite mined through its end use as consumer product. Yet only t mining and processing of vermicui have come under any kind of reg lation. Upon leaving the process plant, vermiculite is unregulated, a those handling it are exposed tc toxic substance with no warning to its presence. Our thanks to Dr. Arthur Rohl, of : Environmental Sciences Laboratory at MotSinai School of. Medicine in New York. , providing us with critical data and recent si dies on the asbestos contamination vermiculite. 15192814 * < j Just When You Thought It Was Safe To: i j 0 Insulate Your Attic ; S cRepot Your Plants | 0 Change :Your Kitty Litter result from Imn Iroimtnl md gardening. respectively " The report goes on to estimate that 136.000 : people 4 year ire e%posed to levels of j atb^sios as high as l 2.600 ux*m^ Jw/ing the \-f vermicular 4*' .iixuia.mn -ill CvO pcoolv live 1 -fi oimirv - ,*.-* w/miruaie A C JI a* a a 11. tnerr are at least J.OOG owners or hobby grernnnuses f wftnir exposure to vermicuioc i should he comparable to that of j | greenhouse employes orrupatiitnrliy Jf rxposeb. Anyone repotting their hnuseplani with potting soil containi mg vrrmirulitf wuult! be exposed 104 : mill amount of asbestos fiber, as would people who hjcuir kitty ittier. ! barbecue base. or vnu pul up their own orywall. piaster, etc The uiniumrr nas no idea what's brine handled None nl these pr.* ducts, from attic muiaion to kitty inter islabrlcd.CPSC apparently out { being sure how to proceed Alter thr ; strong stand takrn in respect to | artitKiai embers anj sparkling com* J pound. e . no sale ex-Hisurr Irvri, ! ihn iMxiu<n is incomprehensible ! The EI*A has June extensive | research into the problems assooj ated with asbestos contamination of j vermuiilite. compiling a wealth of j m!*fnt.tinA on thr- subteff 4? yet I *hrv`vr Jonr ruuhint; with it. issuing I no regulation* or warnings It appc.tr* that *imr a sate lower limn I U*r asbesio* exposure cannot he j kninJ. the problem is bring rtwered | up I lots vise an one esplain that at I A-asi three goxrrnnteni agencies i Sat-r bnrn sltiJvotg j known lot* 1 %*b>iar. occurring m the market t Ha*e. Ie at leai live sear*, and A**t | 4*ne *o muih as rruoire that it be j labeled AmoKer ETA report, also obtained through FOlA. frames the Problem 'Although the quantities of as* W>im rrlraird during end-use of rrrmettiitr are small in comparison to the mine and workplace, thr JJtgrrgair risk to thr consumer of product end user mar he large in Whistleblower Blues "An independent group has found that m% onstitulional right to Itredom of perch has been vndateJ and that top dtnal *n the CPA *n*rtred to JiwreJit me and tried to *np mr irons informing the public and t ngre* about me lailurr of "EPA has a wealth of information on the asbestos contamination of vermiculitc, but has done nothing with it, issu ing no regulations or warnings." view of the large number i peopir exposed. Morrovrr, users may be particularly vuineraolc and unpro tected due to ignorance of the potential haiard.* Using vermicuiitr in an enclosed area, such as an attic, greatly increases the exposure Irvri t asbestos fibers ir. the air. Or a garage. Or a basement. The point is dear, workers and consumers are being exposed to a known ha card without the information tu nandlc n saieiv. >< to avoid it altogether. A* tne iI?A report points out. `There are ade quate substitutes for most Of the uses of vermicular. If vermicuioe were not available, perlite. cellular concrete and fiberglass would be the most common substitutes.' There the matter now *tancs. The tragic consequences of asbestui exposure are weil established. Ver micular is a known carrier of asbestos fibers. Thrsr microscopic fibers are released miu thr atmos* phere from the hmr vermicular is mined through its end use as j consumer product. Yet oniv ihr mining ami processing ni vermicular nave tome under inv un* l e<u '.anon UfMtx ira\ng tnr piani. vvrmcuiitc i unfrcuiaiwi. vnJ iho*e handling u are rxpnsrc to j tone substance with m> earning j> to us presence. j f Q*r fhmeilt h* Dr. ' rr* tarir.vunm/af 5c*n*.n Lmv.fc'.rv .VJ.**.* *:r.ai ,*i Xiniton.' m Xn* Y.v* * ~ pmiaVn^ *r 4ttk o'rtits*: Jit* *tr.a rr.s*a Jin an Cut ai.Sstin .jiMru-li.'ii " rmurvitfr What and Where is Vermiculite? Vermiculite is a naturally occur ring mineral oi the mica lamtiy. It occurs m thin flakes packed tngrihrr in piatr*likr layers. Tiny dropict* ol water are trapped between the layers, providing the mechanism bv which vermiculite achieves its versa tility Healing vermiculite to between j* 1.000* i.COO -degrees Fahreniieit 1 uases the droplets to evaporair. j aikiwing the mica li espanu into ! smail. light weight. low.derini y | prvri. Pure vermiculite can espand j op to thirty times it s original | vniume. Espandrd vermicuinr is known as eilohaied and the heating process as exfoliation. The maiorny ol vcrrmeulitrs uses fall into threr general categories: lightweight aggregates used in construction, agricultural and horncultural products, and insulation. The building industry* uiri vermicu lar m ronercte. piaster, wallboard. and simtiar material. Vermiculite concrete weighs much less than rrgular sand-based concreie and ha* excellent insulating properties. One inch nt vermnuhie concreie has me same insulating capacity as twenty inches of regular concreie. MurJ into plaster nr wallU.arc. vermiculite adds sound deadening and lire resistam proprrttct- A msuiaiion. vermicuiitr is poured loose between ante torn* and into hollow cement block. It's also used as a packaging agrnt to prevent break age dunng shipping. because of us large surface area and abiliv tu absorb water and gal. vrtmicuinr * useu exiensweiy n agriculture andhorticulture. Though most familiar at a soil condmomne agent lor house plants and .r greenhouses, vermicuiitr is also usr^ as a plant growing medium.chemn'ai IrHih/rr earner, pat king maier lai lr nursery vioik. and arrrr jn,, extender lor pesticides and hero** * odes. Vermicuhie s other 'minor' usrs include use as a filler in paints, plastics and rubber, in kills* lilier. anc in barbecue oasr no retain anc re/lrvi heall. Payday for Environmentalists With es*ery pa*Mng public opn*on poll ensxronmeniabsts are getting .their much deserved payout tor years and years of rallies, irach-ms. press releases, tenlrrtntn. brnaJsheen, daym-day-owt meetings, etc. etc. A recent poll, conducted for the Continental Croup Inc., of Stamford. Conn. a maior energy, forest pro ducts and packaging company is significant because, unlike other ptslU. it requited participants to weigh their support for rnsironmrniaJ proirriion again*! *aCh jrxyjblr ahernaii\f* a* slowrt eco- Based un interviews with Uld people selected lomirrm the naiionai population, plus 2oJ corporate exec utives and jti members nl environ mental groups, Ihr survey found* >6 percent of those interviewed lavor maintaining present air pollu tion standards 'even if some lac tones chase as a result.** S >o percent lavor keeping current environmental regulations 'even it n slows the production of more en ergy." * aO percent favor giving prwmtv i ensironmenial cleanup 'even comoanse* ha%e tu charer m*rr ft*r ml ^ .P. T.giiuBwpVWPWB interviewed. perrem from small companies and M percent from 'Fortune >00' companies sad thrrr should be rmphasi* nn cleaning up the environment, even il that re quired them to raise their prices fur goods and xervurs Thr above findings reinforcr earlier pi*ti by two* Harris Am* Ciaies. which round 5J pereeni t Amenfitu /awe krrpng *#e Clean r i i Air Act intact ur stiflenmg it. in thr face ol admsnisltainsn pru^wai* ti rr(a\ standards 15192815 t i i Jk Thk, Vermiculite Asbestos Connection By Daw Portlier with Alice Cave t'v i thoroughly modern product T/or thr lifestyle we**e -jrown ac. ruttomed IO. Vermiculite i light "In I97L the producer of 80% of the weight indnon<ombu*lblr. !t`i free* I lloMinK and mtoiublr. chrmicallv men. rrf:!imi and non-*bra*ive. notion's vermiculite announced that virtually all of their ore was contami Thi* impfmtvr arr ay of attribute* enabiet vermiculite to insulate, nated with asbestos." fireproof. ettenu. lighten, and aerate product* ranging from putting <01! to I concrete, plntri board to kitty liiirr i t In our rfi(Con%umrr rule we've scattered free*flowing vermiculite { about our attic, and we've spread *er mc wit tr-loaded fertilizer onto our Lawns. Unfortunately. in our all too frequent consumer role, we've handled vermiculite I without Innwing that ii'i contami* i *ieu with asbestos. a proven Card* | noyen. EPA Releases Documents Through Freedom of Information refluent Environmental Action Foun* datton Hat been able to evamme EPA documents on asbestos contammalion of vermiculite. Thrse reports date back to 1977. Although vermiculite hat been mined in the United States since 192. no studies on thr health effectl of exposure to thr mineral have been Regulatory Options OSHA. under their broad mandatr lo provide a safe environment tor workers, has two regulatory options with regards to vermiculite.The first is an exposure standard and the second a labeling requirement. Theoretically. OSHA'* current esposurestandardi protect workers even alter the vermtculite has left t ne processing plant. But as an EPA | Contamination Revealed located. Thr effects of exposure to asbestos, on thr other hand, is well report notet.~Reaitstica!ly. however, it is difficult to imagine the standard { The vermicuiilelasbestot ronnec* I Hun went public in |9?l. That'* when VV R. Grace and Co . the large*! dume*ttc supplier of vermicu* lite. revealed the results of tests confirming asbestos contamination in the ore minrJ at their Ltbbv. Montana site, producer of SOHoi the nation * vermiculite ore. In 197a, both the Occupational Safety and Health Administration documented. Ily |9lfl there was enough evi dence un asbestos harards to causr Amrncan and Canadian insurance Companies to Stop selling life insur ance to asbestos workers. The cancer-causing potential of asbestos was suspected as early as the 1930 *. although the lirst standard lor occupational exposure to asbestos wasn't set unttLl97| by OSHA. being enforced at many of these iairr sum For esempie. U is doubtful that employers at grrrnhouset where vermiculitr ts used as a sod condi tioner tun their businesses with thr asbestos standard in mind. Few employers besides those involved n the initial stages of vermiculite processing know that vermiculiie is often contaminated with asbestos.* This is the case with many other tOSHAI and thr Mine Safety and Health Administration got involved when workers in the vermiculite industry, came under regulatory i "|rote<iion`* Irom asbestos du*i l*rtr tn thi* involvement vermiculite *32 of the 221 vermiculite workers tested had lung disorders normally associated with asbestos exposure." workers were exposed to asbestos iu*t cimreniraiion* as.high as 245 libers per cubic centimeter (IfemJj. The new OSHA standard of 2 ffcm^ s even rei'ugmred a* two high In 1979 the Consumer Product Saletv Commission (CPSCl aekrwsw(edged the contamination problem when they ordered a general tludyot thr use of asbestos in consumer products and included "potting matenaP (vermtculilel among thr priWurir t<*be testeih However, the Wigv of the study was later narnwnl to include only products m whwh atbesiiK is wrUMufft added Dave Pontier. a recent graduate of . C*M*grtHkh Um*mitc, gift cum* fueled an mtrrnshsp Htth thr !VaT$ froirrt Akr Cavr is a mrirrhrr : hr an rmironmmtal c*nsulitng } turn J One of the first reported incidences of abetns-tike hralth problems appranng among vermiculitr work ers vi m 1975 bv O.M Scoti and Sons Co., a manufacturer of agrscul* lueal chemicals. Woekes ai ihnr Maryland frriilsirr plant developed lung disorders ssormally associated with asbestos exposure. 01 22! tested. 32 had disorders ranging from libers in the lungs to bloody pleural rflussons. with symptom* ranging from coughing, fatigue and Chest pstn to hypertension. The crucial point is that research on a*beiios<jued cancer in labor atory animals has shown that there s no threshold level below which exposure causes no effect. Therefore, ssnre no safe levels lor atmosphere concentrations of asbrsitH exist. m ean*#r rsK produce a prrceniage-of canrrrt m those exposed industries using vermiculite as well, including construciion--workers. drywaO installers, brick `and stone masons, plasterers, insulation work ers, and anyone involved in commer cial agriculture. Why are employers and employee* largely unaware of vermiculite * contamination with asbestos? OSHA*s.labeling regulations lor asbestos. * ... all (aibrstos-coniaining) raw materials, mtstures. con tainers . "covers vermituhle. but the' regulation is self-service. Com pliance it voluntary as long as * .. a manufacturer behaves that the use (handlMg.1rtorage. etc.) of a product wiO<am create fiber levels above tnr OSHA lunderd." Even thn is ulti mately a 'hr sot point, since OSHA .slated ,m .Aped of )0M that thn expeturr-vandard it sosufftcient m protect workers' health. n.,, >K.,.l.n.urv 0*3 EXPOSURE Vermiculite nest fmdsirs way into the home, where it ts "regulated** by CPSC. Thr Fedrrat Hatardou* Suostances Act gives CPSC thr mandatr 10 regulate haiards presented by ihr presence or use of lOaiC and other haaarduus substance* in the hurne. Like OSHA. they have the authority to ban. rrgulatr. or require iabeis on product*. - | | i l CPSC has already #serened this authority with respect 10 asbesto* banning two consumer pressure containing asbestos liber: jrt.iW.j: embers and ipackling comoou^c Neither is associated with the err- ; miculttc industry. At that timrCPSC ! went so far as to say that there ti no j sate IrveJ of exposure to asbestos in | consumer products, and that, "only j banning these products can adr- | quaiely protect the public from i unreasonable risks of injury assoc?- * aied with them." As was mentioned earlirr. CPSC began a siucv ot asbestos in consumer products over j three years ago. excluding procurt* j like vermiculite which contained asbestos as a contaminant. To datr, ! nothing has been reported. ! CPSC also has the authority to require content labeling ui product* In view of EPA reports concerning j the significant leveis of consumer * esposure to vermiculitr. tin* ac: on. at the very least, should have been taken some years ago. A stufiv prepared for CPA by an independent | Virgma*basedconiultingfirmmakrs j this quite clear. The report state* | Jthat. "Over "4 million persons use lawnand garden lertiliters each year If the fertdirer is verm<utiie*ba*ec. .[ estimated excosure levels m jfO<r*i*t of 4 4 ugrm^* and 25 wgrm^ could This mngfcr method of measuring asbrstm exposure fur.-`m**miUigram per CUOK meterl contrasts with the carher tfkw method 'IrcmWiex-rt per cubic centimeter} in the same v av that a pound of eggs contrasts with a doaenegg* Unfortunately, the Vtrgf nu study we refer to only used thr* weight method, and it's vinua.iv impostiblc for us to correlate the two different systems with the wtforine- uon we have on hand. Further. OSHA only uirt the volume method tn os asbestos standard. Sutfice to say. however, that at ihr general "rule of thumb" regarding nbnim there n no safe exposure trvri. tna.- cates these latter iquin usmi: the weight method are aC lob-tons- dered esirrmefv ha/ardou* | t j j ! j { , 15192816 HAZARDOUS BEDFELLOWS: The VERMICULITE- ASBESTOS CONNECTION Since 1971, government and industry have known that virtually all vermiculite produced in this country is contaminated with asbestos. Why don't the 4 million people who live in homes insulated with vermiculite knOW this ? See page 5 DTOSUKL Envtronwnul Action foundation 7XC Duponi Clrdt Building Wnhinfpon DC UOM iuk tea u.a. aniug. PAIO tem Mo. t)i WooMooian. O.C 15192817 The VERMICULITE- ASBESTOS / CONNECTION "rur .-* xvtc; Waste and Toxic Substances Project ENVIRONMENTAL ACTION FOUNDATION 13^6 Connecticut Ave., NW Washington, DC 20036 202-296-7570 May 1983 $10.00 15192818 DECISION PAPER for ASBESTO S--COOTTAMINATED VERMICULITE ' --A- ./.* 4 ` . ii.: * ' * " 1 *. - Prepared by . v+LzZi *.. . :-;;.Ca*cfJLrr v___r: - . ' " - Albert Colli `William Stigliani " '*' ;'Kirk'' Johnson-.: .=^._ r:.y ... :. '`,-crir'- . .* . ' 1- *> ?!'J, ?Ea$3Sk~2i*.cL:s. - it^ . ' .*** * t ;t ) ^ V* ``u iT* IC^2 ' Chemical Control Division Office of Toxic. Substances-'-r. rn \-; ------- --.... February 19 81. ;-- --; 15192819 XV- BACKGROUND Exposure to asbestos--contaminated vermiculiy workplace end during mining- operations. In December 1978, O.M. Scott and Sons submitted, to EPA regarding serious "health problems'experienced ^ who were processing asbestos-contaminated veraiculite j, chemical fertilizer plant in Marysville, Ohio-1?. The ^ submission indicated that bloody pleural effusions had detected in 4 of 3 50 employees; symptoms and clinical' fin*. .the employees were similar to those found in individuals v; asbestou-related diseases." Subsequent follcw-up studies initiated by OSHA11 revealed that the prevelance of health" problems among employees at O.M- Scott and Sons was "greater originally expected. Thirty-two cases of.pleural and/or. interstitial abnormalities were detected by chest x--rays an spirometric measurements (x--rays were taken-..for 125 of -221 workers). .. . ^ . The cause of the disease was most probably due to'.inha -asbestos dust. Monitorirtg data revealed that -prior to the " installation of more, stringent safety controls in 1976, pla 1employees were occasionally acutely exposed", tol; airborne -f"`- asbestos. _ One air sample taken" iri the unloading areaTwaf f to contain 245 fibers/cni ' Subsequent microscopic' studies' identified -other types -of fibers- and -cleavage products'in' addition to asbestos. Similar high fiber levels have heen reported elsewhere. -A plant in St.. Paul, Minnesota .which-.a "processes veraiculite containing asbestoswas found to have levels as high as 163 fibers/cm3 . at-t-Vim-igVi--p a v health effects, developed bv workers a- Scott & Sons a-npipPT- -t-n be caused bv asbestos erposure, ome factor*! ^^rnnnted. Since little data- exists, for health effects from pure vpmi culite (fibrous or ncnfibrous is possible that cleavage fragments or fibers .of veraiculit itself caused the effects. "Free silica present in the dust another'passible .toxicant. Alternatively, fertilizer "and pesticide chemicals, * which are coated onto the veraiculite surface in the producti'pn process, may "have adhered onto tht fibers that were inhaled and could have contributed :to the adverse health-effects. -Further studies would have to" investigate these possibilities. At -thi3 time, the only kni toxic chemical to which the workers were exposed is' asbesto: The source of asbestos contamination may have resulted the use of vermiculite from Grace mines in Libby, Montana.. acknowledged the presence of asbestos in the veraiculite frc that mine in 1971. In 1977, an EPA study reported the pre of substantial -amounts of asbestifora anphibole fibers j.n t)- tailings (residues) from mining and milling operations. ' .E beneficiation, impurities in the raw veraiculite ore are physically separated by a "wet'*' process in which adhering cl 75 15192820  iher impurities are removed .by washing .However, . attempts ^mbve all impurities have -been -unsuccessful and tremolite Vstos - remains as a contaminant .in the^ vermiculite.' The. rent' asbestos concentration iiji ore leaving the Libby- mines has ortedly been reduced to 0.5%. In the past, mining employees had been exposed to asbestos-' ^containing fiber levels in ex case of. the current OSHA 8--hour TWA [standard of 2 fibers/cm3*7 Current levels in the ambient air tsurrounding the Libby mines range from 0.3 to 2.6 fibers/cmJ* ^Equipment operators are exposed to Levels of'0.6-1.8 . ffibers/cn3, ,, and workers in loading- areas are_expo'sed to fiber . .evels in the 'range from 0.2 to 5 fibers/gm3. To 'date' lung tcarring has been noted in some employees' and there were two . reported cases of "dust related lung diseases", in 1979. ' NIOSH ,s currently conducting a thorough study on adverse health effects of Libby miners..... --A -r-f--.------~"i.. - Release of Asbestos from Vermiculite Products or End Uses". Tn a^d-r-finn to workers,* a substantial number of consumers id nroductend--users are potentially exposed to asbestos from' bbestos-contaninated vermiculite. - ^Although no -data-exists to- instantiate this premise, engineering "calculations have shown lat levels of asbestos' release into the atmosphere'during end.'-" fe may not be negligible. .. - Figure 1 diagrams the' estimated. nints of asbestos released during mining,' production' and use of :'~Tniculite. The greatest source of current' asbestos release to - is during the exfoliation process.' At present exfoliation is itimated to release 140 kkg/yr of asbestos,.-or 58 percent of the' " :al airborne releases. The second major_ source of airborne : jestos is the mining and milling, process,'which is 'estimated to .ease 102 kkg/yr, or 42 percent of the total- "Vermiculite end' ' [es account for.less than'1 percent of total airborne- .eases. Although the'quantitites 'of asbestos released durino: 1--use'-are small m rrimrrair i n I '* "h- -- i" unrKPlace, the= egate nsx to the consumer or -product end user. iTgy'"he large ' .yrsw or the large number of people exposed. ' Moreover, users - be particularly vuiTreidbltf Jiid unprotetmeci cue to ignorance / hazard- ^ " ' 7~- ^ " T " 1------r"---. 76 15192821 V OFFICE OF TOXIC SUBSTANCES 'SUBJECT: ('PRL-1) Review of Priority -Review Level-1 Report- Asbestos-Contaminated Vermiculite FROM: TO: Joseph J. Merenda, Director Assessment Division (TS-792)- C' Warren R. Muir- . Deputy Assistant Administrator far. Testing and Evaluation- (TS--792) -_ - James Raisa, ' Acting Director Health Review Division (TS-792)' ' T-~: " John Ficke,- Acting Director ".'Environmental Review Division (TS-792I'-- Tec adc dec che AD fare AD the tli a he rc: The attached PRL-1 report entitled Asbestos--Contaminated ' .... ^".rmiculite is being distributed for review within- the Office of sting and Evaluation. This chemical was referred to the Chemical. Review ana Evaluation Branch nor- consideration in thePriority Problem Assessment (PPA) process as a potential (backlog) 4(f) candidate.. Consequently, the attached document does not address all potential sources- and effects of the chemical. Instead, it addresses only those sources 'and effects, relevant, to the identified priority problem;, i.e. , the risk of asbestos-related diseases among workers who mine- and process vermiculite. Based`on my review of the PRL-1 report,' I recommend that assessment activities be continued- after completion of data gathering activities to provide additional exposure information relevant to an assessment of risk. In addition to the problem originally recommended for consideration, I also recommend that data gathering and subsequent assessment, activities be exoancej. to lnciuae an evaluation or -the risk to the general po-oul a exon ^ TW-onpv r** j-- pduct s conta_in inc a soestos-contanunared, vermiculite. Because section 4(f) of TSCA as n6t appi'xc'able to . the vermuculite problem (c.f. , Meeting Summary for 4(x) Meeting, May 5, 1980), such assessment activities'should enter the PRL-2 stage of the PPA process without further consideration of 4(f) ^uplic ability/criteria. 102 15192822 KVTERIAL SAFETY DATA SHEET - - H. R. Grace & Cb. 62 Whittcmore Ave. Cambridge, 02140 Number: Z-8303 ncels:. Z-144-2 te Prepared: 9/24/B6 Telephone Number for Information and Emergency Response (617) 876-1400 X-3140 or 3897 CTION 1 - PRODUCT IDENTIFICATION &de Names and Synonyms: HDNOKDTE; MX--4, KX-5 sraical Name and Family: Lightweight Gypsuro-Vermiculite Plaster cnula: Blend of Gypsum Vermlculite, Cellulose and (In MX-5 only) Fiber Glass LL: r Hazard Qass/IDI/Label: Not Applicable (mixture) Not Applicable portable Quantity (RQ): Not Applicable rface Freight Classification: Vfell Plaster ZA-ttilS Hazard Index: Health: 1* Flammabilityj 0 Reactivity: 0 v Personal Protection: E ~10 II- HAZARDOUS IN^REDIENTS/IDENTITY INFORMATION Percent (CAS#, Chemical ft by iredient Common tones)______________Weight Exposure Limits CSHA ACGIH :.al Dost psum may add qp to ; Quartz CAS# 14B08-60-7) PEL * 30Mq/M3 TLV 30M3/M3 Hot Applicable I Quartz + 2 4 Quartz + 3 pirable Dust psum may add Up to Quartz CAS# 14808-60-7) PEL lOttq/M3 TLV - 10Mq/M3 4 Quartz + 2 % Quartz + 2 ilON 111 - PHYSICAL/CHEAI ICAL CHARACTERISTICS ling Point Not Applicable Specific Gravity (HtO 1) 12-15 PCF (Dry BuiX Density) oc Pressure (mm Hg.) None 4 Volatiles None or Density (AIR 1 G obiilty In Water 1) Not Applicable Slight Evaporation Pate TButyl Acetate 1) Not Applicable pH Approximately neutral, variable with water source -stance 'and Cdor Coarse, free flowing grayish powder 15192823 SECTION IV - FIRE AND EXPLOSION HAZARD DATA Flash point (Method Used) N. A. Extinguishing hiedia Not Applicable Flammable Limits None LEL UEL Special Fire Fighting Procedures None Unusual Fire ard Explosion Hazards None Known SECTION V - REACTIVITY DATA Stable; Yes Conditions to Avoid: Not Applicable Incoropatabilltv (Materials to Avoid); prior to welding or cutting, HONOHDTE must be removed from steel surfaces in those immediate areas v>ere direct exposure to excessive heat from the cutting or welding equipment is . possible. Hazardous Decomposition or Byproducts; Sulfur Dioxide SO2 (Due to excessive heat from cutting or welding) Hazardous Polymerization: Hill not occur Conditions to Avoid: Not Applicable SECTION VI - HEALTH HAZARD DATA ; (Include all known acute and chronic.effects, signs, and symptoms of exposure and msiical conditions generally aggravated by exposure) Routes of g*{X<surei Inhalation; Exposure to excessive airborne dust may cause coughing or sneezing. Long tern exposure to Quartz Dust, viiich may be present i$> to 21, can cause risk of silicosiB, pneumoconiosis, dyspnea and decreased lung fimction. Skin and Eye; Eye contact with dust may cause minor mechanical irritation. Direct eye contact with hCNONDTE Spray may cause physical injury. Prolonged or repeated skin contact may dry skin. Ingestion: Not expected to be harmful. Carcinogenicity According to OTP, IARC and CSHA: Not Jfcplicable. Emergency and First Aid Procedures; In case of contact, immediately flush eyes with plenty of voter. Do not tub eyes. Consult a physician. If inhaled get fresh air. If symptoms persist consult a physician. 15192824 #Z-8303 Page 3_ of 4_ SECTION VII - PRECAUTIONS FOR SATO HANDLING AND USE ! ~ Warning Statements: CAUTION! Contains Vermiculite CAS#. 1318*00-9; <^psum CAS# 7778-18-9 and qp to 2% Quartz CAS# 14808-60-7. May be harmful if inhaled. Long-term overexposure to airborne dust may cause silicosis or other lung disease. May cause minor-mechanical irritation to eyes. Direct contact with spray can damage eyes. Floors in spray area may be slippery vhen wet. Precautionary Measures: . Avoid creating dust. Equip mixers with dust covers. Provide, ventilation and respiratory-protection. Wear eye protection to avoid contact with dust, or spray. Post "slippery Vhen vet"' signs where appropriate. Steps to be Taken in Case Material is Released at Spilled: Observe precautions noted above. Rsnove material for disposal. Jtoste Disposal Method: MCNOKDTE waste is not defined as hazardous according to EPA {40 CFR 261.3). Dispose of all waste in accordance with applicable federal, 'state and local regulations. SECTION VIII - .CONTROL MEASURES ' Respiratory Protection (Specify Type): Wear an approved dust mask (NIOSH TC-21C-XXX) to prevent exposure above the limits specified above in Section 11. Ventilation Local Exhaust: Mechanical; Exhaust fans may be necessary vfcen mixing in enclosed areas. Special: Not' Applicable. Other: Not Applicable. Protective Gloves: Stork gloves or hand creams may prevent drying skin. Eye Protection: Goggles are recarenended where exposure to excessive dust or M3NOHDTE spray is likely. Other Protective Clothing or Equipment: Normal work clothes. Work/Hygenic Practices: .'Use'bag opening and disposal procedures which minimize dust release; Equip mixers with dust covers as referenced in the . MONDKDTE Equipment Bulletin. DNI 'zrd'd uoaj 15192825 ee:ei ss. vi eaj 2- implanted in their lungs. This method of introducing MMMF into the mice "effectively bypassed their natural immune systems. The natural question that this raises is "would the same method of implantation of some other fiber such as cotton or nylon, which we are exposed to everyday or of vermiculite which we are also exposed to frequently, also, show the same effects? A symposium on "Occupational Exposure to Fibrous Glass" sponsored by the National Institute For Occupational Safety and Health (NIOSH) was presented by the University of Maryland on June 26-27* 1974. Papers were presented by several medical researchers on their work in this area e.g. "Gross et al, (1971) reported autopsy examinations on 20 fibrous glass workers whose exposure history ranged from 16 to 32 years. The autopsies failed to show evidence offibrotic disease attributable to such exposure. In contrast to this experience populations exposed to other dusts causing disease, for expample, free crystaline silica, or asbestos, show dicernable evidence of pulmonary labnormal ities well within 10 to 20 years. One would expect, that if fibrous glass is a potent cause of chronic bronchitis or pulmonary fibrosis, some evidence of an excess of these abnormalities should be observable by now", and in the comments of this report it stated "Two conclusions are drawn: Fiberglass dust, inhaled and deposited in the lungs, causes no harmful tissue reaction. Fiberglass dust, deposited in the lungs, is readily removed from the lung tissue by the pulmonary mechanism". Also, from The Federal Register Vol. 38 No. 66-Friday, April 6, 1973, "The substitution of ceramic wool, mineral wool, and fiberglass for asbestos is not now known to be a problem. There is no evidence that these cause health effects in the concentrations found in occupational or ambient environments." 15192828 American Energy Products Corporation NEWS-GRAM 88-1 Distribution: All American Energy Products Corp. customers. Dear Customers: , Several of you have called regarding jobs you have lost or on which your bid proposals were not accepted because erf either real or feigned concern about the health aspects of sprayed mineral fiber fireproofing. - This apparently is generated by The World Health Organization (WHO) and I ARC Report on mineral man-made fibers (MMMF) which classifies these fibers as Group 2B; "Possibly carciongenic". I'm sure you have a pretty good idea where these scare tactics ayid propaganda are coming from, but if anyone bothers to read the report they will find the following: 1. Extensive animal inhalation tests by various laboratories have shown that MMMF fibers have no potential to induce cancer. 2. Mice exposed to high levels of airborne MMMF did not have a greater occurance of lung tumors than those that were not exposed. 3. X-ray and lung function studies on current MMMF workers have not shown exposure to mineral wool to be associated with lung abnormality. 4; The only increase of lung cancer in the WHO report ocgicped with mice who had MMMF fibers SPRAYED MINERAL FIBERS 15192827 -r: #c^303 . SUPPLEMENTAL ItgORT-ftTICN - Page 4 of 4 ''I ----. I Cue of the components of thiB product is verroiculite, a naturally-occurring mineral that contains treuolite in the ore body. Except for trace amounts, the tremolite is removed from the vermiculite during processing. It is this purified verrhiculite which is used in the manufacture of MONOKOTE; MK-4 and MK-5. The EPA has stringent standards covering the spray-application of fireproofing materials, with levels below ,001V (10 parts per million), MONDK0TE is more than 1000 times below the current EFA standard. MONOKOTE 4 and 5 are in full conpi lance with all current and proposed Federal regulations and standards, including the proposed EPA ban and phase-out of products containing ccrrmercially-added asbestos. Using sophisticated, state-of-the-art electron microscopy analysis, it may be possible to detect fibrous tremolite in H3NOKDTE at .levels of .0011 (10 parts per million) by weight or less. Copies of such independent laboratory test results by Arthur D. Little, Inc. and Mt, Sinai Medical Center" are available upon request. On June 20, 1986 the United States Occupational Safety and Health Ain ini strati on (OSHA) established new stringent regulations regarding occupational exposure to airborne asbestos fibers including tremolite. OSHA regulations include a maximum Permissible Exposure Level (PEL) of 0,2 fifcers/cc (8 hr. time weighted average) and an action level of 0.1 fibers/cc. Grace frequently monitors jobsite exposure levels for workers applying MCNOHDTE; HK-4 and MK-5, All tests have shovn exposure levels consistently below the OSHA action level. OSHA has officially informed Grace that its asbestos regulations are not meant to be enforced for any products which contain "de minimus levels" of naturally-occurring tremolite where exposure levels to employees do not exceed the OSHA action level. ^ the data included herein are presented according to W. R. GRACE i CO.'S PRACTICES CURRENT AT THE TIME OF PREPARATION HEREOF, ARE WADE AVAILABLE SOLELY FOR THE .-CONSIDERATION, INVESTIGATION AID VERIFICATION Ct THE ORIGINAL RECIPIENTS HEREOF AND X> NOT CONSTITUTE A REPRESENTATION OR WARRANTY FOR WHICH GRACE ASSIMES LEGAL RESPONSIBILITY. IT IS THE RESPONSIBILITY OF A RECIPIENT OF THIS DATA TO R1MAIN CURRENTLY INFORMED ON CHEMICAL HAZARD IFORMATION, TO DESIGN AND UPDATE ITS OWN PROGRAM AID TO COMPLY WITH ALL NATIONAL, FEDERAL, STATE, AID LOCAL LAWS AND REGULATIONS APPLICABLE TO SAFETY, OCCUPATIONAL HEALTH, RlOfT-TO-KNOW AND ENVIRONMENTAL PROTECTION. 15192826 -3- Eurisol, UK Mineral Wool Association which studied and were involved with the WHO renort. state the fnllnwinn in their path ii.no mo7 Mineral Wool and Health - A Summary "Unlike asbestos, mineral fibres have been cleared by the World Health Organization (WHO) of any link with mesothelioma, fibrosis or any other non-ma1ignant respiratory disease". Also from Lhe same summary: "There is no evidence that mineral wool presents any risk to production workers today, or has done so for the past 20 to 30 years. In the general environment, levels to exposure are minute compared with the factory situation, and no hazard is posed to the public. The UK Government has stated that on the limited evidence available the risk to househo1ders-from insulating a loft for instance-is negligible although sensible precautions should be taken by using dust masks when applying." The American Conference of Governmental Industrial Hygienists (ACGIH) in their 1987-1988 TLVs, Threshhold Limit Values and Biological Exposure Indices, list the TLV of mineral wool fiber, the same as 3 nuisance particutales, 10 mg/M , and higher than Grain Dust (oats, wheat, barley) at 4 mg/M , and of Talc at 2 mg/M respirable dust. Portland Cement and Gypsum both products we are exposed to regularly 3 also have a TLV of 10 mg/M the same as mineral wool. The fact that some of these studies go back more than 10 years should assure us all that with the proper precautions and good housekeeping taken during the application of fiber fireproofing, neither the applicator, allied trades nor the general public is exposed to anything more than with other common everyday substances that should also be handled with good housekeeping practices and care. I hope the foregoing is helpful to you. 'Please advise us of any project or architect you feel we should contact regarding this. Sincerely yours, M. E. Herrera President MEH/rw 15192829 Enclosures 1isted: Occupational Exposure to Fibrous Glass TLVs - Threshold Limit Values and Biological Exposure Indices for 1987-1988 General Industry Safety Order 5155AIRB0RNE CONTAMINANTS Federal Register Vol. 38 No. 66 Friday, April 6, 1973 Mi seel 1aneous Information (4) 15192830 General Industry Safety Order 5155 AIRBORNE CONTAMINANTS Nov. 1986 S-600 -------------- ------------------- dR Sun ! | 0eo*9c OtwkmciitA, Governor | Ron H*a*Wv O**ao* ol fteunom I TITLE 8 (H.^rtr CENERAL INDUSTRY SAFETY ORDERS 55155 (p. 41L270.13) TABLE AC-3 PERMISSIBLE EXPOSURE LIMITS FOR MINERAL DUSTS Suiatxocv SILICA (1) Amorphous (Including natural diatocnaceous earth) -- (2) CryanlHrxr Quartz (respirable) ____ __ __ Quartz (total duit) Cristobalite ____ -......... Silica, fund_________________ Tridynrite---------------------------- Tripod (reapirahle) -------------- PEL mppcf'" mg/M` 20 -- -- 10 > 300 ftl %SiO, + 2 30 %SiOa + 10 SiO, + 3 Use ooe-half the value calculated from the formulae for quartz. ,U*e the value calculated from the formulae for quartz. .U*e ooe-half the value calculated from the formulae for quartz. -- 10 %SiO, + SILICATES (lea than 1% crystalline sUca)(A Asbestos (inducting actinolite, amodte. antbophyUita. chryaotile. croddolite. and OocooUte), aee Section 3206 Craphite (natural) _______ Mica ---- , , . ____________________ Mineral wool fiber_______________________________ Perlite------------------------------------------------------ Portland Cement________________________________ Soapstone------------------------------------------------------------ Talc (fibrous. nonfibroui and mixture) ,*1------------- Treroolito, noaubesdform....................... 13 20 -- 30 X X -- X --10 -- 10 2 ii COAL (BITUMINOUS) DUST <5% quartz, respirable fraction ___ -...... ................ . >3% quartz, respirable fraction ________ _--........... -- -- 2 ',1 10 1,1 %SiO, + 2 NUISANCE PARTICULATES <1% quartz Total duit_____ _______ ___ ____________ _________ Respuahle duit ........ _.............. ........... ............................ > 1 % Quartz--use appropriate formula for crystalline silica....................... .................. ................ -- -- |0 3 <1 MCfcm of pnrttciee pw MMr foot wi wkt. bammi on aac*a oouatwl bv Ufhi4WU tciuuf: mppd X SJ todWto rwwbi per cvbe nw or [mith o* pm cmCoe wamiwwf. lb) Tb prowime of i*O* ( n- wilitwi bai to tSa Iwaul* m tba uhubi iioniui>oi fna usfeoro* -upfr MBipf to gw wwonct *r+*mm otbm wcba^ hiw ba to ba aopbcobto. O flnlb TO it rnifinmnw n ~ parranupi iW VHi 111 m~nil)lni aif I n--ft frr Ttto brill M|_ii>iTioM>toi firwii rl-- fractw paam ut Matw mli Cm fnfbmnj thanrtoitotor.a ftm* ibwaf Nowti t * ------------------------- ..._______ _____ ___ L3-------------------------- -------------. ---------------- -- T3 iJ- - -------------------------------------------------------------------------------30 3.0__ ------- - - ------------------------------- X3 10------------------- --------------------------------- 0 br trmaJhim mlkeo. (I All faptfamaao of Wtoon UOi Aabaaw. dmil dm opph- 27 15192832 TLVs THRESHOLD LIMIT VALUES and BIOLOGICAL EXPOSURE INDICES for 1987-1888 ISBN: 0-936712-72-4 Second Priming Ameri Confere of Governme; Industrial Hygien 1^1 *> DUSTS In iirns eciiion ot me TV.V list. Ousts are also listod in the mam aionaboncai listing. Starting with the 1980-1909 edition, ousts will Oo listed in mo main alphabetical list ing only. Substance SILICA, sic; TLV-TWA CrystalTM Quartr" 114808-60-7] 0.1 mc/m1. Respirable dust Cnsiccaiiie"' ............ .. .0.05 mg/rn1. Respirable dust |:4a6i_;C'-i! Silica, lusec"1 160676-66-0] ..... . .0.1 mc.'iti*. Resoirable dust Tricvniie-............... .. .0.05 mg'm1. Respirable dust [154GS-32-3] Tripoli1" ...................... .. .0.1 mgrm1 of contained respirable 11317-95-9- quaru dust. AmcrpriO'js Diatomaceous earth (uncaicmed)'*'........ ... 10 mg/m1. Total dust 168555-54-9) " Precipitated silica-".. ... 10 mc/m1. Total dust * Silica ger*' ............... ... 10 mg/m\ Total dust SILCATES Asbestos1"1 Amosite ................ .. .0.5 fiber/cc. A1 (12172-73-51 Chrysolite ............... .. .2 fibers/ce. Al (12001-29-5) Crocicolite............... (12001-28-1) Other torms ........ .. .2 fibcrs/cc. A 1 Mica-(12001-25-2) . .. .3 mgrm1. Respirable dust Mineral wool liber ... 10 mgrm1 Perlite-1 ..................... ... 10 mgrm1. Total dust Portland cemenr" . .. . . . 10 mem1. Total dust Soapsionc ............... .. .3 merm1. Respirable dust"' b mem1. Total dust'*' Talc (containing no asbestos libers)" 114807-96-6] ........ .. .2 mc/m*. Respirable dust Talc (containing asbestos libers) ... Use asbestos TLV-TV>'A. However, should not exceed 2 mg'm1 respir able dust. 38 OTHER DUSTS Barium sulfate'*1 17727-43-7)...................... 10 mg/m1, Total dust 'Coal dust"' ........................2 mg/m1. Respirable fraction Gram dust (oats. wheat, barley)............... 4 mg/m1. Total particulate t'Graphite-' (natural) (7782-42-5)....................(2.5 mg/m\ Respirable dust) IGraphiie. synthetic*' .-..(10 mg/m1. Tout dust) Nuisance particulates'*' (see Appendix 0).........10 mg/m1. Total dust ' t See Nonce of Inteneed Changes. * 1987-1988 Adoption. (01 Fibers longer than 5 Mm ana with an asoect ratio eoual to or greater than 3.1 as determined by the memprans tiller metnod at 403-4 JQX magnihcation (< mm ootecnvei pnase contrast illumination. (e) The value is lor total dust containing no asbestos and <1% tree silica. (f) The value is lor dust containing <5% Iree silica. For dust containing more than this percentage ol free silica, me environment snouid be. evaluates against the TLV-TWa ot 0.1 mgrmJ lor respiraole quaru. The concentration of resoirable oust lor the application ol this limn is to 0c determined from me traction passing a sire-selector with me charac teristics delmeo in the "c." paragraphs cl Appendix F. (i) The concentration ol respirable oust lor the application of this limn is to be determined from me fraction passing a size-seiector with the characteristics delmeo in the "e." paragraphs in Appenoix F. 39 SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 10-K ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For ibc fiscal year ended December 31, 1935 Commission file number 1-3720 W. R. Grace & Co. Incorporated under the Laws of the State of Connecticut I.R.S. Employer Identification No. 13-S114230 Grace Plaza. 1114 Avenue of the Americas, New York, New York 10036-7794 212/S 19-5500 Securities registered pursuant to Section 12(b) of the Act: Tiilr or fS clivi Ninrx of rrb rxchin;c on -hicS rnjintrrv) Common Stc-ck. SI par value........... 4Yi% Convertible Subordinate Debentures Due March 1. 1S90 12HS Notes Due '990 i 21vi*o Notes Due 1990 6:.n^ Convertible Subordinate Debentures Due 1996 lOY.Ta Notes Due 1997 111493 Sinking Fund Debentures Due 2003 59b Guaranteed Sinking Fund Debentures Due 1986 (issued by W. R. Grace Overseas Development Corporation] New York Stock Exchange. Ir.c. Midwest Stock Exchnxgc, Incorporated New York Stock Exchange, Inc. Securities registered pursuant to Sccrion 12(g) of the Act: None Indicate by cbeck mark whether (be registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months and (2) has been subject to such filing requirements for tbe past 90 days. YesL_bl_ No------ The aggregate market *Jue of \V. R. Grace Sc Co. voting stock bcid by oonaCiliate; was approxi mately 52.2 billion at January 15, 19S6. At March 7, 19S6, 4],S23,335 shares of W. R. Cracc & Co. Comrooo Stock. 51 par value, were outstanding. DOCUMENTS INCORPORATED DY REFERENCE Oootir^i Where 1 pcorpon ird )9S5 Annual Repon 10 Shareholders (specified portions) Proxy Statement for Annual Meeting to be held May 9. 19S6 Paris I and II Part 111 PART I Item J. Business. Introduction W. R. Grace Si Co. is primarily engaged in the chemical business on a worldwide basis, as well as in natural resource activities related to energy and in consumer and other businesses. Grace's chemical operations involve the production and sale of specialty chemicals and, to a lesser extent, agricultural chemicals. In natural resources. Grace engages in the exploration for and development and production of oil and natural gas and the production of coal and supplies services and equipment to the petroleum industry. Grace's consumer activities consist of the operation of restaurants and retail stores. Grace is also engaged in processing cocoa and chocolate, book distribution, manufacturing specialty fabrics and cattle breeding services. Grace has approximately 94,000 full-time employees worldwide. W. R. Grace Si Co., incorporated in Connecticut in 1399, conducts substantially all its foreign activities, and some United States activities, through subsidiaries. As usee in this Report, the term ''Company" refers to W. R. Grace Jc Co., and the term "Grace" refers to W. R. Grace 4: Co. and/or one or more of its subsidiaries. Grace's principal executive offices are located at Grace Plaza. 1114 Avenue of the Americas. New York, New York 10036-7794. and its telephone number is 2! 2/S19-55CO. 7h:s Report on Form 10-K. is accompanied by Grace's I9S5 Annual Report to Shareholders.' Where this Rerort refers to information in the accompanying Annual Report, such information is incorporated bv reference herein. ' Recent Developments Purchase of Shores end Financing Thereof. On January 2. I9S6. the Company purchased 13.6 miiiicn shares of its Common Stock and shares of its preferred stocks (collectively, the "Shares'') previously owned by Friedrich Filck Incustricvcrwaitung KGuA, a West German company, for a purchase price of S59S.1 million; this purchase price was equal to the market prices of the Shares on December J. 15S5 pius certain transfer taxes. The funds used to purchase the Shares were raised with proceeds of Si 19.S miiiicn from a December 1935 offering of 2.6 million shares of Common Stock and with S473.3 million of bank borrowings which were subsequently repaid with commercial paper bor rowings. To effect such bank borrowings. theCompany obtained additional lending commitments from certain of its revolving credit banks. To permanently finance the purchase of the Shares, the Company issued S250 million of 7% convertible subordinate debentures in the Eurodollar market in February 1986 and is considering addition.'! debt and stock financings. Further, management decided to sell Grace's Retail Group (see "Sale of Herman's" and "Industry Segments--Retailing" below) and is also considering other divest ments and restructuring alternatives. .. Prior to the purchase of the Shares, the Company obtained from certain of its revolving credit banks and institutional lenders waivers of loan covenants which wouid otherwise have been violated by the purchase of the Shares or tbe related borrowings. These waivers cxpircon March 31. 19S6. The Company believes that further waivers will not be required, and that it will be in*compliance with these covenants, principally by reason of the classification of Grace's net investment in the Retail Group as a current asset, the Common Stock and debenture offerings referred to above and the temporary refinancing cf certain long-term borrowings with snort-term borrowings. Further information regarding these developments-and related matters is provided in Notes 1 and i4 to Grace's Consolidated Financial Statements and Management's Discussion and Analysis in the accompanying Annual Report and in "Sale of Herman's" and ''Acquisitions, Divestments and Restructurings" below. 1 1519283P Scle of Herman's. On March 19. 1936. the Company and Herman's Sporting Goods. Inc. ("Herman's"), a publicly held subsidiary included in Grace's Retail Group, entered into agreements pursuant to which The Dee Corporation PLC ("Dec"), a United Kingdom company, would acquire all of Herman's outstanding capital stock .(including 6.440.000 common and common equivalent shares owned by the Company) for S35.25 per share, in cash. The acquisition is being made initially through a tender offer that commenced on March 21. 1986. to be followed by a merger; the Company has agreed to tender its Herman's shares in the tender offer. The Company expects to report an after-tax gain of approximately SI 10 million from the sale of its Herman's shares to Dec and to use the proceeds from such sale to partially repay the borrowings incurred to finance the purchase of the Shares. In addition, a portion of the proceeds m3v be used to make open market purchases of up to 2.4 million shares of the Company's Common Stock. It is anticipated that the sale of the Company's Herman's shares to Dec will be completed in April 1986. However, the sale is subject to a number of conditions, including approval by Dee's shareholders; consequently, no assurance can be given with respect thereto. Industry Segments Information concerning the sales, pretax operating profit and identifiable assets of Grace's indus try and geographic segments for 1983. 1984 and 1985 is contained in Note 16 to Grace's Consolidated Financial Statements (sec the Index to Financial Statements and Schedules on page F-l). Certain of Grace's businesses arc seasonal in nature. Sec the "Quarterly Summary" on page 40 of the accompanying Annual Report. Specialty Chemicals Grace s specialty chemical operations consist of the manufacture and sale of approximately 90 separate product lines in seven broad market groups. The following tabic shows these market groups and the principal products Grace manufactures and sells in each. Market Croup Princioil Products Packaging ..................... Energy and Automotive Construction................. General Industry......... New Technologies Graphic Arts................... Chemical Intermediates Plastic packaging products, foam trays and related application equipment; can and other closure scaling compounds and.equip ment; metal working lubricants Petroleum cracking catalysts; adsorbent molecular sieves: flotation and buoyancy modules for deep-sea drilling; emission control cat alysts: battery separators: sound deadening and corrosion control materials; specialty adhesives and coalings Concrete admixtures: fireproofing and insulating materials; spe cialty sealants; roofing and waterproofing materials: horticultural products' Industrial catalysis: adsorbents and dehydrating, flatting and thick ening agents: industrial cleaning compounds: paper industry chemicals: tape backings: water and waste treatment and pollu tion control chemicals Coatings for printed circuit board fabrication; conductive and dielectric polymers: specialty electronic ceramic packages; adhe sives for semiconductor circuit packaging: microwave absorbers and electromagnetic interference shielding; laboratory and com mercial-scale ultra-filtration membranes and equipment: chro matographic systems; membrane equipment for medical applica tions; technical industrial ceramics, anti-ballistic composites and other molded parts Letierflex and Ne*>sfiex processes for making plastic printing plates using photosensitive polymers and related equipment; specialty drying equipment and printing blankets Hydrogen cyanide derivatives; emulsion polymers: dispersing agents: pharmaceutical and hcrbicidal intermediates: organic sulfur compounds 2 15192837 In addition, in the New Technologies market group, a plant to manufacture nitroparaRins began intermittent operations in 1935, and production is expected to begin in the second quarter of 1986. See "Acquisitions. Divestments and Restructurings" below for information concerning a 1985 acquisition in the New Technologies market group and "Specialty Chemicals--Sales by End Market" on page 30 of the accompanying Annual Report for information concerning the sales of each of the above market groups. Grace's specialty chemical products typically represent a relatively small portion of the cost of the end products in which they are used. Accordingly, competition is based primarily on technological capability, customer service and product quality. Specialty chemical products arc produced in approximately 140 plants worldwide (a majority ol which arc located in the United States) and arc sold primarily through direct sales organizations. Most of the raw materials used in the manufacture of Grace's specialty chemical products are available from multiple suppliers (see "Materials and Energy" below). In addition, Grace supplies certain of its own raw materials, including vermiculitc from Grace mining operations in Montana and South Carolina which provide its vermiculitc requirements for construction and other products. These operations yielded approximately 253.000 tons of vermiculitc concentrate in 1985. and Grace estimates that its proved vermiculitc reserves (excluding those currently without mining facilities) arc sufficient to sustain production at this rate for at least 40 years (sec Note 15 to Grace's Consolidated Financial Statements). Consequently. Grace does not presently anticipate the need to construct additional vermiculitc mining facilities. Various governmental agencies have expressed concern regarding the le-. cis of naturally occurring tremolite asbestos contamination associated with the mining and process ing of vermiculitc. However. Grace is in compliance with current tremolite asbestos exposure stand ards and believes that the implementation of proposed stricter federal exposure standards would not adversely affect its vermiculitc business. Vermiculite ana pxpducts using vermiculite account for less than 55* of Grace's specialty chemical sales. See Item 3, "Legal Proceedings." for information concerning asbestos litigation to which Grace is a party. Agricultural Chemicals Grace produces and markets ammonia, phosphate rock ar.d fertilizers, as well as livestock feed and feed supplements (see "Agricultural Chemicals--Sales by End Market" on page 31 of the accom panying Annual Report). Fertilizer products include diammonium and other phosphates, anhydrous ammonia, urea, nitrogen solutions, ammonium nitrate and a variety of granular mixed, blended and fluid fertilizers sold for direct application or for use in the production of compound fertilizers. Grace's agricultural chemical products arc primarily sold in the United States; however, its phosphate rock and nitrogen and phosphate fertilizers are Mso marketed abroad. Grace also has a 51% interest in a partnership with Cetus Corporation to develop, manufacture and market biotechnology-based products for agricultural use. *. Grace produces ammonia and other fertilizers in 20. facilities in the United States and Puerto Rico, two in Trinidad (one of which is 49Tc-owned) and one in Jamaica. The following :. blc shows the estimated I9S5 annual production capacities of Grace's agricultural chemical plants and actual 1985 production (inducing Grace's share of partnership and other partly owned plants). Production was limited in 19S5. primarily due to continuing worldwide ovcrsuppl.ies. , Location United States Puerto Rico Trinidad Jamaica Product Ammonia .......................... Urea........................................... . Mixed/blended/fluid fertilizers . Converted phosphates'.............. . Phosphoric acid 100'* P;0; Nitrogen solutions...................... Ammonium nitrate .................. . Mixed/blended fertilizers.......... Ammonia (c) ..;....................... Mixed/blended fertilizers.......... Estimated Annual Production Capicm .at 621.000 tons 400.000 tons 1.280.000 tons 1.900.000 tons 752.000 tor.s 330.000 tons 120.000 tons 135.000 tons 66 J.000 tons 50.000 tons 1985 Production .490.338 tons(b) 322.1 17 tons 603.555 tons 1.226.254 tons 559.716 tons 242.441 tons 100.094 tons 57.5S0 tons 59 3.31T tons 29.980 tons /ooinoiti on df pofrl 3 15392838 PB 258 869 OCCUPATIONAL p EXPOSURE TO \*\ U.S. e'*"TUtyj6?))i1ti,lDuCATl0N and welfare / cnlf far n\ 'S >NN" ' WCLFA*E/Pwbllc H..Hh S.r,ie, mwvfxto ti NATIONAL TECHNICAL INFORMATION SERVICE 01 Cd*<(lC( tniftC'iUD. va. uui 1Q?P3Q demonstrate no adverse health effects in'ceras of thronie bronchitis or pulmonary fibrosis. Cross cc al. [1971] reported autopsy examinations on 20 fibrous glass workers whose exposure history ranged from 16 to 32 years. The autopsies failed to show evidence of fibrocic disease attributable to such exposure. Ir. contrast to this experience, populations exposed to other du9ts causing disease, for example, free crystalline silica or aobuoeos, show dlscernable evidences cf puinnarv abnormal idea weil within 10 to 20 yeara. One would expect, that if fibrous glass is a potent cause of chronic bronchitis or pulmonary fibrosis, some evidence of an excess of these abnormalities should be observable by now. No scudy thus far referred to ha9 been designed to Investigate the full post-employment period and the possible carcinogenic effect of the exposure experienced by workers in fibrous glass manufacturing. A study of the mortality pattern of employees of the oldest USA glass wool plant has beer, carried out by XIOSH and will be reported at this symposium. A preliminary report of this study by Wagoner [1974] Indicated that no excess of malignancy of any kind was observed. The only cacegory of disease shoving a possibly significant excess was in "other respiratory diseases of a r.on-saiignanr nature exclusive of influenza and pneumonia." Of the 17 cases in this caregory, the majority were said to be emphysema or 'orpulmcnalc. Only 5 of the 17 had any mention of fibrosis on the death certificate. In none of these could the likelihood of exposure to free crystalline silica or coal dust be excluded. The Importance here is the absence of an excess of bronchogenic or Cl cancer or mesothelioma. It is clear that the health experience of those exposed for long periods of time to airborne fibers in the manufacturing of glass wool for insulation or other purposes is not in the same category a3 those employees exposed to another fibrous material, namely, asbestos. There are several possible explanations for this difference of human experience. There is evidence that fibrous glass introduced directly into the lungs of experimental animals does not evoke the name severity of in::amatory and fibroginic response characteristic of asbestos fibers even though comparable amounts of the same sizes of fiber are used. (Kusehner, 1974 and Cross, 1974 ] The reason for this, is not clear but may be related to the fact that g'ass is amorphous while asbeoros Is crystalline. They are of different chemical composition ever chough both are silicates. Hence, their surfaces night behave differently when in contact with living cells. Measurements of the concentration of respirable size fiber in the work-place where glass insulation is cade or used, demonstrates the level is far lower for glass than for asbestos which has been produced or used. In the period of exposure responsible Cor the disease now occurring, acoescoa fibers of cozsparnblc respirable sizes were 10 or more tines as numerous as glass fibers. [Johnson et al, 1969] The lung residue of employees manufacturing fibrous glass shows many times fewer fibers per gram of lung clasuc than la observed in the lung residue of persons occupationally exposed to asbcscos. [Cross cc al 1971 and 1374] This nay be due co the lower concentration of respirable fibers in the fibrous glass 239 / gram-of-dry tissue basis was somewhat higher in fiber glass workers chan In the control population. However, the average mineral fiber concent (opt.ically visible as well as E-M site) of the satellite lymph nodes was larger In the control group chan In Che fiber glass group. In addition ..to this daca, study of the mineral sediment remaining after digestion of the lung clscue showed thac some fibers had irregular contours [Cross cc al, 1970a] and some fibers were apparently derived from diatom fragments. [Cross cc al, 1971b) Ocher work had suggested thac many fibers may be pnytoliths, derived from the ashes or smek.e of burring plant products such as leaves, paper, wood, or coal.[Cross cc al, 1971b) Comments It should be lcmiediaccly apparent chat the identity of the fibers counted and measured Is unknown. Some of chcm are doubtlessly glass. Some may be of other vitreous material such as rock wool and core than a few may be asbestos fibers, inclusive of crenolice from cosmetic calc. Some of the E-M size fibers may also be diatom fragments. It is probable chat a large proportion of the fibers are derived from the skeletons of planes (phycolichs). These have been demonstrated in the ashes of paper and wood. [Cross ct al, 197 lb] In view of the fact that the dimensions of the fibers isolaced from the lungs of the two population groups and the distribution of the dimensions arc so similar, one is tempted to conclude that the bulk of the fibers in Che two groups are therefore probably composed of Che same material and derived from the same basic source. This conclusion could be flawed by the fact Chat che lung Is an excellent Size-selector and therefore, although the size range of the fibers is similar, they may be composed of different materials. An indication of this is seen in che wide vsiriecy and irregularity of shape of the fibers seen in che sediment of lung digestion. [Cross ct al, 1970a] Two conclusions seem inescapable, and these, arc: Whatever che composition of the fibers in the lungs of the fiber glass workers, their presence evoked no recognizable tissue response. A tissue response may have been present; but if it was present, it was so mild as to be unrecognizable. Fiber glass workers, exposed to fiber glass dust for 16 to 32 years, harbor fibers in their lungs similar to findings in the lungs of the control population with regard tn quantity and dimensions. It is interesting to consider Chat the quantity of mineral fibers found in the lungs from Pittsburgh, most of wnleh were women, represents a 'background" quantity, an amount that Is (or has been) inherent in urban living and that has produced no dlsccrnable cissuc reaction. Since fiber Blass workers have no more chan this "backgro- ".d" quantity of mineral fibers in their lungs even after 16 to 32 years of exposure co the dust of Blaus fibers, it would seem thac either the fihglass dust to which the vrkcrs had been exposed was not respirable or, as seems more likely, if it v#s respirable and had been deposited in che lungs. It was prompely removed ky the pulmonary clearance mechanism, leaving only a "background" quantity of fibera. 262 15192841 The data obtained from studies-of the lungs of long-term fiber glass workers arc in agreement with the conclusions derived from previous anin.nl experiments (Cross et al, 1970b) Chat: Fiber glass dust inhaled and deposited in the lungs causes no harmful tissue reaction. Fiber glass dust deposited in the lungs is readily reooved from the lung tissue by the pulmonary clearance mechanism. Pathologic.nl examination of Che lungs of long-term fiber glass workers .ns well as determinations of the pulmonary mineral fiber content disclosed chat no discernible tissue reaction to fiber "lass dust was present and that the average quantity and dimensions of tr.c mineral fibers in the lungs of fiber glass workers were very similar to those of the mineral fibers in the lungs of a control population. Two conclusions are drawn: Fiber glass dust, inhaled and deposited in the lungs, causes no harmful tissue rcacCion. Fiber glass dust, deposited in the lungs, is readily removed from che lung tissue by the pulmonary clearance mechanism. REFEP.ENCEJ 2. Davis JMC, ' Cross P: Are ferruginous bodies an indication of atmospheric pollution by asbestos? Presented at the Conference on the Biological Effeccs of Asbescos, Lyons, October 1972. (Conference Report Jn Press.) 2. Cross P: Pulmonary alveolar aural sclerosis. Arch Environ Health 6:1114017m 196 3 3. Cross P, Cralley LH, Davis JMC, de Trcville KTP, Tumo J:A quantitative study of fibrous dust in the lungs of city dwellers in Walton, VH (ed.): Inhaled particles (ed 3), 1970, Old Woking, Surrev, England, Unwin Bros, Ltd, Thp Cresham Press, vox 2, pp 671- 81. 1971b ^ 4. Cross ?, Kaschak M, Jolkcr E3, Babvak HA, de Trcville RTP:The pulmonary reaction to high concentrations of fibrous glass dust. Arch Environ Health 2.0:696-704, 1970b 5. Cross T, Tuna J, de Trcville RTP: Lungs of workers exposed to fiber glass--a study of their pathologic changes and their dusc content. Arch Environ Health 23:67-76, 1971a Cross P, Turna J, de Trcville RTP: Fibrous dusc particles aod ferruginous bodies--methods for quantitating them and some results from che lungs of city dwellers. Arch Environ Health 21:38-46, 1970a 263 15192842 HAZARDOUS BEDFELLOWS: The VERMICULITE- ASBESTOS CONNECTION Since 1971, government and industry have known that virtually all'vermiculite produced in this country is contaminated with asbestos. Why don't the 4 million people who live in homes insulated with vermiculite know this? See page 5 D&OSURi EfMrennxnui Adlan framrinkm 714 Duponl Clrdr OulUfcng Wohingran DC UOM I j i Nvpm Km U.S. P4JO Permit No. toAAAmpiort. O.C 15192843 ' JusiWhen You Thought It Was SafeTo: i | S Insulate Your Attic S-. Repot Your Plants Change Your Kitty Litter mull from lawn treatment and gjruenmg. respectively " The report I ^ur> on to rtiiffliir lhal IfiO.OOO : propif J year are rsposed 10 levels of j as high as D.buQ uri'ni^ during :nc *t v.*rmiculte #" t .o^uimr C . C"0 peonh* live .r. i-nmrs msi........... ... vt-rimcuinr A c J. io n ,* i!. : i r f i* air 41 least J.TCO ..wnrrs oi ho?bv greennuuse* wnox' exposure !> vrrmicuiite i xKuulJ Sp vo^pjrjtlr in that of a j gfrrnimoxe rinn'tivri oci upahonally j r\;HnrJ Anyone repotting ihrtr Km,>rplani with potting soticontam* . mg \ rrmn ulttr would hr e xposrd 10 4 ,maJJ rfmimm of at>r>in> tibrr. at wxulj r*t*upic w bo har.ale kit ly in tr r. J Darbnur 'jjvr or ^hu put up theif i own :rvwjj(, plaster, el( ^ TK.: un>uinrf has no idea whai's ! bring nandirU S'onr nl these pr.. ducts, from ainc muiitmn to kitty lutrr liblH'irj cTSC apparently not bemg >ufi* now io proceed After the siM'ni; stand liken m rrspect to . jrdlicu! embers jnJ sparkling com* i i* . <ii 4lr *;Hsre lrs-ei. ! :ris lo.u'tion o income-irhensihie | The Cl'A hit uonr extensive research inio ihp problems assort* jjrd *\ it h asbestos i nniuminanon of I prmii iiiitr. tompilmg 4 wealth of !i,-r>,iiinn on ihp jiiPiefl h* yri nrv r ooihuu; with n. is*oug no M'lf.ii.ilions or Aiming it appear* ih.il inr a sate lower limit :or jxCrio* es|,`sirp sannot he lonnd. the problfm ts being Coveted ! iots voe i an nnr explain that at :fw*r jjiurr'ntrni agencies <oi I....... stuJsmg j known ioh i.iunir muiiiflii in the market plj c. lor at ipii lise srar. and Aot ! dom* s' imuh 4> renoire that t be !.hetpu Anothrr P \ report. also .Warned through KOI A frames the t profvrm | '.Although the quantities of as- i bestus rrlmrd during rnd*utr of vermifulur are small in comparison | to the mine and workplace, the | jggrrgatr nik to the (ontumrr of I ptcducl end user may be Urge m j i Whistleblower Blues ; " An independent crsup hit found | that mv onstitulional right to ( lirrdom of speech hit been vuitateJ jnJ iha; lop otIn4t* in the CPA . on.r reJ to Jitcrrdii me jnd tried to *t*p me irom informing the puhln j"w Wimgrei* about the fiilurr of /*..( fi.iif, . ihr publ'i "EPA has a wealth of information on the asbestos contaminat ion of vermiculite, but has done nothing with it, issu ing no regulations or warnings." view ot the large number oi people exposed. Morros'er. uer rruy be particularly vuineraolc and unpro tected due to ignorance ot the potential harard.*' Uiing vrrmicuitlf m an enclosed area, such as an attic, greatly merrase* the espoiurr levri to atbeiio* fibers in the air. Or a garage. Or a basement. The point is clear, workers ami consumers are being exposed to a known haxard without the information to nandte it lateiv. ur to avoid it jitogpie.rr. As tru* t?A re|xiri points out. There are aue* quaie substitutes for most of me uses of vrrmiculitr. if vrrmicuiite were not available, perlite. criluUr concrete and fiberglass would be the most common substitutes." There the matter now stands. The tragic consequences of asbestos exposure are well established. Ver* micuiite is a known carrier or asbestos fibers. Thre microscopic fibers are released into the airm*s* phere from the nme vermiculiif is mined through its end use as a consumer product Yei only ihr rr.tnmg and prt;rsting ot vrrmicuiite hjve come undrr any kind ci feeu- lahon Ui'ifn iractiig me prtr>>nc plan l. vi*t rrvvjluc i ..nfi'C^.aifC, j;id I hose handling ii are ecpos**d u> > toxic substance with no warning j> to ns presence. ' 0*r rJrirtii /. Or. Arthur II ./ ;i: (nririuniimrai ,VMmc Lahv .torn, u* .VJaxttf hrnjf > .i< Mniiff*!.* `n N/i- Y*ri *" kt wifii. Jaia arj rr.rm uv Jm 3" ir.f Still rrmuruittr j---------------------------------------------------------------------------------------------------------------------- l What and Where is Vermiculite? Vermiculite is a naturally occur* ring mineral of the mica fimnv. ft occurs in thin lukrs packed together i m plate*itke layers. Tiny droplets ot water are trapped between the layers, providing the mechanism by which vermiculite achieves its versa l tility Healing vrrmicuiite tooetween 1.000*4.COO -degrees fahr'enfsrii i lauses the droplets to evapnrair. I allowing the mica to expana wslo j small. Jighiweig hi. low -density i picves. Pure vermiculite can expand up to ihirty times it's original volume. Expanded vermiculite is known as exfoliated and the healing process as exf%diaii<in. Tlie maioeiiy ul vermtculiie's uses fall into three general categories: lightweight aggregates used in construction, agricultural ana horti cultural products. and insulation. The building inausiry uses vermicu lar in concrete, piaster, wallboard. anJ similar material. Vermiculite concrete weighs much less than regular sand-based concrete and has excellent msuUnng properties. One mh oi vermuulite concrete nas me same insulating capacity as twenty inches oi regular conereie. Mora into piaster nr wallbsard. vermicuhie adds sound deadening and tin* resistant properties As insulation. vermKuliie is poured lotise between attic (Oisls and mic hollowcement block. IT* alsuused as a packaging agent to prevent breax* age during shipping. because of os large surface area and abiiov tu absorb water and gas. vermiculite *s used exiensiveiv m agriculture and horticulture. Thougn most familiar as a soil iondiuomr.c agent tor house plants and .r greenhouses, vrrmicuiite is also useas a pi.int growing medium.cS**no - ter tili/er car rri. pat king mairrial 11*' nursetv vici k. and arrter an- mender lor peshCidrs and hrro>CiCrs. Vermiculite* other "minor" uses include use as a Idler m paints plasiu s ano rubber, in kitty litter, ana in barbecue oase no retain and reflet t he at. Payday for Environmentalists With every passing publu optn*s>n pc'll environmrmalistt are getting their much deserved payout lor years and years ol rallies, teach-ins. press releases, conferences, broad* sheets, day-in-day-ouf meetings, etc. etc A recent poll, conducted for the Continental Croup Inc ..of Stamford. Conn . a maiur energy, forest pro* dus t t and packaging company is significant because, unlike uther polls, it required participants to neigh thru support for environ mental protection against such po'uhlr jitrrnaiise a vl.nser rCO* Based on interviews with Uld people selected to mirror the national population, plus ZdJ corpx>rate exec* utives and JaJ members of environ mental groups, the survey lound penent oi those interviewed favor maintaining present air pollu tion standards "even if some lac tones dose as a result.** t ) percent favor keeping current environmental regulations ''even it o slows the production of more en* ergy." oO percent favor giving pnonii ! en\ ironmental cleanup "even o companies hai r to change m<*re l*r interviewed. perreni from smal companies and M percent frurr "fortune >00" companies said therr should be emphasis on drantng ur the environment, even if that te quired them tu raise their prices f* goods and servnes. The above findings rrinfu'C' earlier p.ll* by Louis Harris Asso Ciates. which tounu 5J percent Americans lavor kerptng me Oca< Air Act intact ur stiffening it. m lh> fair of aJrmmWiaiion prs*ps>a*.> relax slandarJs 15192844 The Vermiculite Asbestos Connection By Dave Pontirr with A Her Cave ?M i thoroughly modern product for the 'lifestyle -jrown ac- eustomrcto Vermiculite it light weight ind n<*M<ombuvl.blr li t free* I lowing i mc ir. loiublr, chemicaiU rrrr. rrs.iicr.: and r'.on-jbrasive This irnr-'e >iv r iff J v ol J 11 fiCUf r> rn^oirt fir, i c u i: i r to i n s u I j t e. i see on -'*. e ifHL' lighten. anc it' at p<iviu. i > i j i>>:nom pot t mg soil to ir. pu\`n .* * r C to M v It 11 ff !n ou' <ionwjmrr rule wr vr Ujfit rrc ! re I iuwng vprmicultir aooui our attic. and wr'vf spread yrrmuuiiir-ioidf j /r r onto our iawns. Unfortunately. in Our ji! i on Irrgurni i mt.t contunrr r 4 * I r. kr w handled vpfmu'uiiir wii.'inui inowiri; `h.u it \ contami* ntirc *.t!i nborot. a proven Can't* nutfn j Contamination Revealed , Thr vrrrr.jculiiriaibesio* ronnrc* Mun Wtm pi: hill* m I 97 1. That t wltm tV R Crace and Co. thr i ij i ge> t domestic supplier ot vrrmtcu* '..if r r v r j l r . the results of tests i confirming jsbestox contamination J m the orr mined it tlinr L;bb*. Montana >>te. producer of SOS- ol thr nation * vfttMi uiitr orr >n 197*. both thr Occupational Safety and Health Administration | tObHAl jno thr htinr Safety and | Health Administration got involvrJ when Hivvf'i m thr vrrmKuinr ; mout'M came unOrf regulatory \ 11 r i*j r i 11, i\ ! r o if. * Or > t it t O u v I I I'lior to i !u* i*u oive ment vrrntu uM r | wi>am rtf exposed 10 asbestos <Jusi concentrations as high at 2ai j libers prr *ubic centimeter fflcm-^J j Thr nr*. 0$MA standard ol 2 flcm^ i ik fvrn recognised it tuo high j In 1979 thr Contumrr Product j Sjtrtv Coinnmiwn (CPSC) acknow ledged thr com munition problem tv hen they order rd a grnrrjl ifuJv ol thr utr ol asbestos in contumrf producis inj included "potting materia!" it*rrmtfu!ilr) among thr products ti* br tested -However. thr w ipr ol (hr Hudy wii later narr*wrJ to mcluJr only product* m whfch asbesto* ii adJrd | Dj% r Pontrer. 4 recent graduate of l .n*crt.**n I'nivrrsitc. tutl f\m- piend jn .urnhip with thr \VaTS !*<%'i\x Aim- v. .ik r > j rrsearchrr kMtn .ii*. rru uonmrr.ui consulting I H .T "In 1971, the producer of B0% of the nation's vermiculite announced that virtually all of their ore was contami nated with asbestos." EPA Releases Documents Through Freedom ol Information requests Environmentjl Action Foundatum ha* been ablr to examine EPA document* on asPestos COntamina* non ol vermiculite. These report* date back io 1977 Although vermiculite has been mined in the Unttrd States since 9?. no studies on the health ef/rcts of esposurr to thr mineral have been located The effects Of etposure to asbektos. on the other hand, is well JiVtimrntrd. Hv t1h there wj enough rvi* demr on jsbetint narard> to cause American and Canaman insurance companies ti> stop tei!<ne, Mr msut* ar.cr to asoestos workers Thr cancrr<ausing potential ol asbestos was suspected as early as the 1930's, although the first standard lor iViUpationa! exposure to asbestos wain l set unlit 1971 by OSHA. Regulatory Options OSHA. under thetr broad mandate to provide a safe environment tor workers, has nvo regulatory options with regards to vermiculite. The first ts an exposure standard and the second a labeling rrautremrnt Theoretically. OSH.A's Current ex* posure standards protect workers even after the x*rrmtcuiite has left tne processing plant But as an EPA report notes."Realistically, however, it is difficult to imagine thr standarc being enforced at many of thrse Ijirr tors For raamplr. it it doubtful that employers at greenhouses where vermiculite is used as a sod condi tioner tun their businesses with ir.e asbestos standard in mind, rrw employers beside* those involved m the initial stages of vermiculite processing know that vermiculite is often contaminated with asbestos.*' This is the case wuh many other "32 of ihe 221 vermiculite workers lested had lung disorders normally associated with asbestos exposure." One of the first reported incidences of jsbrttos-like health problems appearing among vrrmicultir work* er * wai in 1976 bv CM Scot I and $on Co., a manufacturer of agricul tural chemicals. Workes at ihnr Maryland fertiitirr plant developed lung disorders normally associated, with asbestos exposure. 01 2 tested. 32 had disorder* rangsng from fibers tn the lungs to bloody pleural rffusioni. with symptoms ranging from coughing, fatigue and chest pain to hyperirnston. The crucial point n that research on jshriiowiuted cancer m labor atory animals has shown that there is no threshold level below which exposure causes no effect. Therefore, since no safe lesrfs for aimewphrric c*ncrntrAtitint of asbestos exist, am* will produce a perernugr of kjnrrrs <n those rxpissed industries using vermiculiir as wefl. including construcJion -waarkers. drywall installers, brick and stone masons, plasterers, insulation work ers. and anyone involved in cummer * cu! agriculture. Why are employers and employees largely unaware of vermiculite s contamination with asbestos* OSHA's labeling regulations lor asbestos. ** ... a Is laibestos-coniam* ing> raw materials, mixtures, con tainers . " covert vermiculite. but the' regulation is self-service. Com pliance if voluntary as long at'* a manufacturer believes that thr use (handling, ftorage, etc ) of a product will not create fibre levels abox-e tor 05H A standard." Even this is ulti mately a rr. mj\ point, since OSHA ataied.in .April of I960 that thi* exposure Mandard is insufficient in protect workers health Vermiculite next finds its way into the home, where it ts "regylalrd" by CPSC. The Federal Hjurdouv Suostances Act gives CPSC me mandate to regulate hazards presented by roe prrsencr or use of toxic and other hazardous substances m thr home Like OSHA. they havr thr autnontv io ban. regulate, or reouirr iabeis on products. f j j < CPSC has already exercised this authority with respect to asiiexu*' banning two consumer pr<;uut'*x containing asbestos t;ber. art.4...j.' embers and sparkling compounc Neither ss associated with tne ve*- j micuiite industry. At that time CPSC ! went so far as to say that there ts no { sate (eve! of eiposurr ro asbestt m j consumer products, and that. ~oniv I banning these products can aue- i quately protect the public from ; unreasonable risks of injury associ ated with them." As was mentioned earlier. CPSC began a tiuc or { asbestos m consumer products uver | three years ago. excluding prooucts J like vermiculite which contained < asbestos as a contaminant To date. *1 nothing has been reported. ! CPSC also has the authority to require comeni labeling ut product* In view of EPA reports concrmri; i the significant levels of ccnsumi-r 1 exposure to vermiculite. thix ac: :n. at thr very least. hou:d have peer* taken some years ago. A tuCv prrparrd for EPA by an independent 1 Virginia-based consulting firm makr* } this quite dear The report states ` that. 'Over 74 million persons use | la wn a no g ardrn lerti!iarrsra(hyi*ar t! the feriiltzrr is vermicuSite-baseu ' estimated exposureirvelsu* aso--'\*x uf 4 4 uKfm^* anc IS ug lowiu 'This tnnjJir method of measuring asbrtim exposure lut'-m^-miKiqram* per cubic meter! ctsniravts with t.-.r earlier rtiemr met hoc ff rem`-titvrs per rube centimeter) m thr sjme wax that a pound of eggs contrasts with a dozen eggs Unfortunately, the Vtrgi- ma study we refer to only used th:s weight method, and >t's virtua.it ?woimpossible for ui to correlate thr different systems with the inform.a* lion we have on hand. Fortner. OSHA only uses the volume methud tn its asbestos standard Suthcr to say. however, tha: as ihe general "rule of thumb* regarding isb-**im there ti no safe exposure trvs-i. m.i>* cates these latter tiguers us>r*c the weight method arr a!! Its U iims.. dercJ extremrlv ha/^rdnu* ! ! | } * { j 1 j j | t SSC2 RULES AND. RPGUIATION5 .siniulnnli/crt reference method has not been developed 10 quantitatively deter mine the content of asbestos In a ma terial. there arc acceptable methods available, based on electron microscopy, R-htclmr.dcpcndent laboratories have de veloped. Dctcrminlnc the asbestos con tent of a maicrlal with these methods costs approximately $300. and the results arc .vrui.iic within plus or minus $0 percent: these limits on accuracy were taken into aernunt In establishing the 1-percent limitation. The proposed standard would have prohibited Lite surfacing of any roadway with .v. hr si os taillncs- The promulgated standard applies to all roadways except those on nrc deposits: these roadways arc' temporary, and cmuiul measures taken to comply wah the Bureau of Mines reg ulations prevent them from being a major source which must be covered by the standard promulgated herein. At this lime, the api'.ier.uan of asbestos tailings to public roadways is not widely prac ticed. but because uf the close proximity of roads to the public, a ban' on using asbestos i.'.il.mv. on roadways is included in the promulsatid standard lo avoid a future problem and slop tire practice where it is followed. The term "surfac ing" is defined to include the deposit of asbestos iaiitr.es or. roadways covered with snow or ire: therefore, this practice is prohibited. Consideration was given to including provisions :r. the standard requiring proper disposal of the asbestos material ecr.cratcd during demolition and eoliceted it: control device* used to comply with the rc'ri.rcmcnts of this standard ft was tircidcd that this was not neces sary be: ..use the Occupational Safety ar.ii .-.f!rti:::ij.:r.-.i:o:i regulations ra err. i;.;o S.ta'lv < include l.ouscheepmg aiui v. astc disposal requirements. Tiii-e reguirmons require lhat any as bestos waste, eonslgtied'for disposal, be coliertcrl and disposed of in scaled imiifrav.r.lr i.ags or oilier closed, imperme able eeiuan.crs. The potential environmental impact of the ;i: eiu uiratcd standard was evalu ated. and it was concluded that the staticald will not cause any adverse ef fects Th.c potentially adverse environ mental c.'.crts of the standard are: Hi The a>nc:tss-tnatcrials which will be co'lcc'.ed in. control devices and genc.-.mcu i:u:-.nc deni.vlittan will have to be cispr.sed of or rreyrlcd. T -i-ueh. as mineral wool, rriau . - ,-,ol. and f.iicrclass. will be substtiuivif for aper:os presently contained in sprav-apui.v d fiicproofing and insulat ing matciials. in rome .r.anufaci uring operations, a major po: :::.u of the asbestos-material relict tec iiv ; a brie filters is cutter re cycled to i hr mrcss or is marketed for other uvs. For example, one asbestos tex tile mill rceyeics large quantities of longcr-fiber asbestos lor process use and sells more 'liar. 90 percent of the remain ing collected mater.als to a brake lining manufacturer. Consequcnlly. a signifi cant portion of the Increased quantities o: "waste'" asbestos materials winch will irult la.::: the lmplviaetilaiiim of Lite standard will not require disposal. Where disposal Is required, the OceupaUoual Safely and Health Administration regu lations (29 CFR. 1910.33a(h)) require that any asbestos waste, consigned for disposal, be collected' and disposed of in sealed Impermeable bags or other closed. Impermeable containers. The contamina tion of ground water supplies with asbes tos from landfill disposal is not consid ered a potential problem. Tlic substitution of ceramic wool, min eral wool, and fiberglass for asbestos is not now known lo be a problem. There Is no evidence lhat these materials cause health effects in the .concentrations found In occupational or ambient environments. Although the standard was not based on economic considerations, EPA is aware of the Impact ($5) and considers It to be reasonable. Costs among the various sources covered by the standard arc quite variable. Although the standard may ad versely affect some Individual plants or companies which are marginal opera tions. It appears that such effects will be minimal and the impact lo the asbestos industries as a 'whole will not be large. RcrcacNccs 1. Cooke. W. E.l Fibrosis of the Lungs due to the Inhalation of Asbestos Oust. Brit. Med. J.. 2. 147. 1924. 2. Cooke. W. E.: Pulmonary Asbeslosis. Brit. Med. J.. 2. 1024-1025. 1927. J. D.-ccssen. W. C.. J. M. Dillavalle. T. I. Edwards. J. \V. Miller, nd Jl. n. Savers: A Study of Asbestos la the Asbestos Textile In dustry Public Health Bull. 241. Washington. U.S. Government Printing O.Tlce. 1333. 12G pp. 4. McDonald. S.i History of Pulmonary Asbcstosis. Brit. Med. J.. 2. I623-;32G. 1327. 5. Mcreweihrr. E. It. A.: The Occurrence of Pulmonary Fibrosis and Other Pulmonary Altcctlons In Asbestos Workers. J. Ind. Hyg.. 12. 133-222. and 12, 233-257, 1330. 6. Mills. R. G.: Pulmonary Asbestosis: fieport of a case. Minn. Med., IJ. 435-439. 1030. 7. Soper, vv. D.: Pulmonary Asbcniosls. A report of a case and a review. Am. Rev. Tuberc.. 22. 571-584. 1930. t. Do riser. O. M.. J. S. Fault?:, and M. J. Stewart: Occupational Cancer of the Urinary Bladder In Dyestuffs Oper.vivcs and of the Lung in ASbestoo Textile Workers and Ironore Miners. Am. 3. Ctin. Path.. 2S. 12C--134. 1355. 3. Braun. D. C.. and T. D. Truan: An Epidemiological Study of Lung Cancer :r. As bestos Miners. Aren. Ind. Health. 12, 634653. 1958. 10. Buchanan. W. D.: Ashestosts and P.-trr.arv Intrathoracic Neoplasms. Ann. XT. Acad. SCI.. 122. 507-518. 1965. 11. Cordova. J. F.. H. Tesiuk, and F.. P. Kr.iiutsou: Asocmosis and Carcinomas of it.c Lung, cancer, li. 1181-1:37. i 12. Doll, n.1 .Moriallly from Lung Cr.nrer ::t Asbestos workers. Brit. J. Ind. Med.. 12. 81-85. 1955. 11. Dunn, J. E.. Jr., and J. M. Weir: A Prospective Study of Mortality of Several Oc cupational Gioups--Special Emphasis on Lung Cancer. A.-eh. Envlr. Heal;:-., 12, 71-7C. 1568. 1 11. Dunn. J. C.. J-.. and J. M. \Vc:r: Cancer Experience Of Several Occupational Groups Followed Prospectively. Am. J. Pub. Health. 15, 1367-1375. 13C3. IS. El wood. P. C.. and A. L Cochrane: A Follow-up Study of Workers f.-cm an Asbrsios Factory. Urn. J. Ind. Med., if. 304-307, 1364. 1C. Emcrllnr. P. E.l Mortalur Among As bestos Product Workers In the United Stales. Aim. N Y. Acad. Set.. 122. 15C-1G5. 1555. 17. Eiitcrllnc. P. E.. and M. A. Kendrick: Asbcsuis-dust Exposures at Various Levels and Mortality. Arch. Enrir. Health. IS, tsi186. 1967. 13. Gloyne. S. R.: Pneumoconiosis: A His tological Survey of Necropsy Material in 1.205 Cases. Lancet. 1. 810-flu. 1951. 19. Issclbachcr. N. J.. M. Klaus, and H. L. Hardy: Aabcatosis and Bronchogenic Carci noma: Report of one autopsicd case and re view of the available literature. Am. J. Med.. IS. 721-732.1353. 20. Jacob. S.. and M. An.ip.veh: Pulmonary Neoplasia Amo.-ic Dresden Asbestos Workers. Ann. N.Y. Acad. Oct., is:. l.10-5in. iocs. 21. Kletr.fclO. M.. J. Mcssite. infl o. Iteovman: Mortality Experience in s Croup of As bestos Workers. A.-c.h. Eavir. Hcslth. is, 177IBO. 1967. 22. Knox, J. r.. R. 5. Doll, and :. D Hill: Cohort Analysis of Changes in Incidence of Bronchia! Carcinoma In a Textile Asbestos Factory. Ann. N.Y. Acad, Sc:., ft; 626-531. 1905. 2J. Knox. J. P.. S. Holmes. R. Doll, and I. D IIIll: Mortality from Lung Csneer and Other Causes Among Workers in ar. Asbestos Textile Factory. Brit. J. Ind. Med.. 2S. 233-303. 1966. 24. Lleben. J.: Malignancies in Asbestos Worker*. Arch. Envlr. Health. JJ 619-621. TSCfl., 21. Lynch. K. M.. and W, A. Smith: Pul monary Asbeslosis. IK. Carcinoma of Lung in Asbestos-silicosis. Am. J. Cancer. 14. 56-64. 1935. 25. Mancuso. T. P.. and A. A. El-Altar: Mortality Pattern Ir. a Cohort of AsOesios Workers. J. Occup. Med.. 9. 147-162. 1967. 27. McDonald. J. C.. A. D. McDonald. D. W. Gibbs. J. Slcmiatyckl. and C. E. Rosalie:: Mortality in the Chrysolite Asbestos Mines ar.d Mills of Quebec. Arch. Envlr. Health. 22 G77-G8G, 1371. 2. Merewether. E. R. A.: Asbeslosis and Carcinoma of the Lung. In: Annual report of the chief Inspector c. ?:wi.f.-.r l.-.r -rrr 1317. London: M. Y. Stationary On.ee. 1949. 79 pp. 29. Xctehouse. M. I.: A Study nr :j*.c Mor- o: Warners :n ar. Asbestos Faciorr. Ur::. J. !:.d. Mec.. ?C. 234-201. I SCO. 39. Sclitorr. 2. Cijurg. and E. c. Ham* rr.ond: Asbcsios Exposure and Neoplasia. JAMA. ISS. 22-25. 1964. J:. Dorow. M.. A. Cor.ston. L. I.. Livcrr.ese. and N. Sedaiet: Mc$o:>.el:oma i:d Us Associ ation Aabctids. 23; -37-351, 1057. 32. Elmes. P. C.. W. T. E. M:Ciu;.ncr. and O. L- V.*adc: 0n*.ire Mcsotiiclicma of use Pleura and Asiiestes. 3ri*-. Med. J.. 330- 333. i?55. JJ. Elmes. P. C.. and O. L. Wade: Relation - shtp Between Exposure ic Asbes:o$ and Pleural MtUdstaace lr. Ann. N.Y. Acad. Set.. JJ2, 545-337. l?C5. J J. Enticknao. J. D.. and W. N. Sr.;i:ber: Peritoneal Turner n Aaucsios:i j. Ino. Med .:chu. K-Jflrr. r. O. s J. c. and L c. \V:.r::tr: Exposure :o ASbeiios and Mc5r:iirh* o:v.a or :Ae Tlcum. Q;:l. Med. J.. 2, 221-2S3, 1054. J5, Hammond. E. C.. T, J. Sel.Waff. and J. Clsurj:: Neoplns'.a Amor.e J.nsr.lsuon Workers In :l;e l?m;rd Slates Special Reference lo imrA.Miuor.vmal NropUsta. Ann. N V. Ac mi. sci.. 519-323.1055. 27. Koursfca.ne. D. 0*0.: T..c P.tiPeUr:y cf MeaotPeMnma ar.d ar. Analysis ol Tlictr soc;a::on vSih Aiocstos Exposure. Thorax. ,r9 256-278. ;:.C4. JJ. Lieben. J.. and H. Pidaau'k.i: Meso::.<!!cma And Asbesior. Esnosurc. Arc?>. E::vir. HeMth. JV. 355-5C3. 1557. JJ. Mann. R. H.. J. L. Cmr.r. a!*.<l W. M. OD.uiJiell: Mracti.eiiomn Asvx:atcd w:;j; A'oOcmosiS. Car.ccr. :5, 52i-22C. i?55. no:***: xccisua. voi Jfl no *6-h:ay. Arm <., 15192846 American Energy Products Corporation Wesiern Plant 1049 Industrial Park Orem. Utah 84057 (801) 224-5905 March 28, 1988 CORPORATE HEADQUARTERS 1175 EAST GARVEY SUITE 101 COVINA. CA 91724 (818) 915-1428 TLX 2B4470 AEP UR FAX (818) 331-2587 Eastern Plant Texas Plant Raritan Center, Building 736 Edison. New Jersey 08837 (201) 225-0228 FAX (201) 225-2191 6717 Polk No. 8 Houston, Texas 77011 (713) 923-4933 RETURN RECEIPT REQUESTED CERTIFIED Mr. Bill Grimes Dallas County Commissioner Court 411 Elm St. Dallas. TX 75201 RE: Dallas County Criminal Court Project. Dear Mr. Grimes: We are the manufacturers of Sp'rayDon, a mineral fibre based fireproofing used to fire protect structural steel. SprayDon has been used over the past 11 years on thousands of projects both in the Government, public, and in the private sector. Some of our contractor customers have notified us that they were told by a Mr. Pidgeon, the job architect on the above referenced project, that he was not going to accept any material other than Monokote, aproprietary, competative material. Since this is a publicly funded project we question whether the restriction to a single product is permissable. Our product has all the necessary UL required fire tests. It is accepted and listed by the three major .governing code bodies in the United States. In short, we meet all the required specifications for this project. We don't mind losing a project in a fair competative manner. Competition is the backbone of our American System. We do however strongly object to being ruled out of even bidding on a project that has been funded by tax dollars. Vfi respectfully request that you provide us with the reason as to why our product cannot be bid on this job. 15192847 Mr. Bill Grimes Page 2 March 28, 1988 I have enclosed brochures and technical data on our SprayDon product along with a signed statement and Corporate Seal that our product is asbestos free. I have also enclosed a copy from the Char 1ottsvi 11e Observer regarding a publicly funded project where only one product was accepted. Thank you for you prompt attention to this matter. If you desire additional information on our product, or if you feel our information regarding the above is not correct, we would be most happy -to discuss it. Awaiting your early reply. Sincerely yours, AMERICAN ENERGY PRODUCTS CORPORATION M. E. Herrera President MEH/rw end: Sweets Brochures, Technical Manual for Architects (1.), and Asbestos Free letter. cc: Mr. Don Olson Assistant Project Architect Henningson, Durham & Richardson 12700 Hillcrest Rd., No. 125 Dallas, TX 75230 (end ). . ' cc: Mr. Pidgeon Job Architect Henningson, Durham & Richardson Box 15547, N.E. Station Austin, TX 78761 (end). cc: Mr. Don Mills Project Engineer Clearwater Construction Co. Box 15547, N.E. Station Austin, TX 78761 (end). cc: Mr. Randy Barr Project Manager Box 15547, N.E. Station Austin, TX 78761 (end). 15192848 - American Energy Products Corporation Western 1049 Industrial Park Orem, Utah 84057 Plant (801) 224-5905 CORPORATE HEADQUARTERS 1175 EAST GARVEY SUITE 101 COVINA, CA 91724 (818) 915-1428 TLX 284470 AEP UR FAX (818) 331-2587 Eastern Plant Texas Plant Raritan Center, Building 736 Edison, New Jersey 08837 (201) 225-0228 FAX (201) 225-2191 6717 Polk No. B Houston. Texas 77011 (713) 923-4933 RE: Federal Building Miami, Florida Job #87-116 , B 1 do. #FL-006122 Contract HGS 04P-86-EX-C0002 We have been informed that our product SPRAYDON has been rejected on the above referenced job because it is a rockwool mineral fiber based product. This rejection was said to be based c-n a resort by the World Healtn Organization International Agency for Research on Cancer (IARC), which classifies man made mineral fibers as "Possibly carcinogenic to humans". To exclude mineral fiber fireproofing on the basis of the above is contrary to GSA Specifications. GSA Specification AIA/SC/GSA: 07256 (3/84) lists two types of fireproofing materials under Part 2 Products. 2.01 A. Sprayed-On Mineral Fiber Fireproofing and 2.C1 B. Sprayed-On Cementitious Aggregate Fireproofing. We do not believe that any individual or group of individuals on a ouolicly funded project can arbitrarily refuse to accept a product wnich meets the requirements of the specifications of the pertir.ani government agency i.e. GSA project, GSA Specifications , anc especially since the UL Designs listed in the specification is for a mineral fiber product. We strongly object to the reason given fur the rejection and feel it is arbitrary. The World Health Organization study on fiberglass showed an increase of lung cancer on mice, but only to those mice whose immune system was bypassed, and the fibers were mechanically implanted in the lungs of mice. Mice which were exposed to hign fiber levels of airborne fibers showed no difference to lung cancer than those that were net exposed. We also must point out that "Possibly Carcinogenic" is nebulous. B*th NTP and OSHA regard man made mineral fibers as only a'nuisance dust1, not as a carcinogen. On che other hand asbestos is a "known- -carcinogen", and we have been informed that the representative for the job architect, Mr. Jeff Savin has accepted 2 products by the same manufacturer. One or' the products knowingly contains asbestos contaminated vermicuiite 15192849  >era 1 Building .1 i ami , Florida Job #87-116. Bldg. #FL-006122 Contract #65 04P-86-EX-C0002 PAE 2 The other product is not contaminated with asbestos however, their M50S information on the product shows that it contains 11 Fiberglass the ingredient that supposedly is of concern because of the WHO Report. Please be advised that we are prepared to appeal this arbitrary cecision to GSA Headquarters Office in Washington, DC, The Small Business Administration ' (SBA), and the Attorney Generals Office in Washington, DC. Please inform us of your decision, or if you^require additonal information on this as soon as possible, so t^at we will know how to proceed. Sincerely yours, AMERICAN ENERGY PRODUCTS CORPORATION M. E. Herrera Pres i dent MEH/rw ends: Hazardous Bedfellows: The Vermiculite Asbestos Con W.R. Grace 10K Report, and ASBESTOS-Explcring the Options. cc: Rubin Turner Attorney at Law Turner, Gerstenfeld, Wilk & Ticerman cc: PhilKaplan Kaplan Insulation Distribution: Jeff Savin Office of Public Building & ReaF Property Design Construction Division Chris Hayward Dar.vi 1 le-Findorff Jose Fieto Fraga & Fieto Architects Peter Gordo Fraga & Fieto Architects