Document wKgRd5q270jbyO7Mn3GGbL7KQ

PLAINTIFF'S EXHIBIT ife25 I Street, nw. Washington. DC 2000fcj 202-872-1080 UC-3663 p=] Organization Resources is] Counselors, inc September 27, 1982 Memorandum TO: FROM: SUBJECT: ORC Occupational Safety and Health Group ORC Asbestos Task Force Darrell K, Mattheis New Safety Limits for Asbestos Recently ORC received a copy of a news release from the Health & Safety Executive of the British Health and Safety Commission concerning tighter future limits for exposure to asbestos. The Commission makes the point that their new limits are not "absolutely safe levels", for it is as yet not clear that a "safe" level of exposure exists. Attached for your information is a copy of the news release discussed above. It is to be noted that the English have recommended a three level approach to controlling exposure to asbestos. One reason that this is feasible is the generally accepted premise that Britain has little if any crocidolite. The U.S., on the other hand, has used a considerable amount of crocidolite in the past; and it continues to be used in varying amounts today. (JLvji0 Darrell K,, Mattheis DKM/sel Attachment UCC 008618 Health & Executive 7) Chtprl Snwi WO 4Q1 1f*T*WW tf* J?T e%> 235 News Release 27 August 1982 Kev Safety Limits tor Asbestos Tbe Bealtb and Safety Coamissloo la to Introduce neb tl|htcr control Halts lot Asbestos from 1 January 1913. Work la to b undertaken te Identify what further measure* can ba takas. St lta meeting as 21 August tba Ccaalssioo decided that tbe Halt for aabeatoa la general uae (ehrysotlle or white aabaatoa) should be helved te ] t/mi. The Halt for aaoalta (brevo aabeatoa) Mill be quartered te 0.3 f/al and tbe strict control Halt for croddellte (blue aabeatoa) will be maintained at lta current leetl of 0.2 f/ml which affectively rules out Its oae. Although a peat aany workplaces ere keeping exposure below 1 f/al (cbrysotlle) a algslflcast ouaber are net yet doing so. 11 they cannot Introduce practical engineering controls to meet tbe new Halt by 1 January 1913 the work force will be required to user suitable protective equipment. The CcocleeloB eaphealses that these control Halts ere oat absolutely safe levels. They noted that assertions had bean Bade that there was new aedlcal evidence about the affects of exposure te asbestos. They 'therefore decided that a detailed review of ell tbe aedlcal evidence to dace should be unaertekan by an internettonally recognised authority In this field. Is tbe abort term they have sated the Eeputy Director General of the Bealtb and Safety Executive (Dr bancaa) to bring together e group of medical experts to consider whetbar tbeie bad bees any substantial changes to Bcdical knowledge since the Advisory Committee oc Asbestos prepared Its report. The Ccmslssloo also decided to act up a Working Croup Including both aides el lneustry. chaired by a senior officer ol the Bealtb and Safety executive, with the object ot idtntllylng end recommending any further measures for tbe control of exposure to atbeatoe duet that were not conslserea practicable at tbe time of tbe ACA report. This would Include s review of present engineering controls eoa systems el work. A review will also be eoKittloeed to aeseas tbe adequacy and the problems ol veering suitable respiratory protective equipment end preteetlve clothing. Bore ^ UCC 008619 The Conciseloo will consider the reports of the Working Croups not lster tbsn August 1963 when they will take Into account Recommendation 10 of the ACA Final Report which states "we recommend that legislation should be prepared naklng clear that an over-riding requirement to reduce exposure to asbestos dust to the minimum that Is reasonably practicable should be applied". The Working Croups will have considered the implications for Industry of the new llmit fron 1 January 1963. If the reporta indicate that further action needs to be taken on the question of control llsits, the Commission will then consider how this should be done. The Commission has already decided, at its meeting on 20 July 1962, action to deal with a number of hazards on asbestos. These are: (1) The licensing of asbestos insulation contractors (considered by the ACA to be a group at greatest risk). (2) The prohibition of spraying of asbestos. (3) The prohibition of the use of asbestos in insulation. (4) The prohibition of the import, use and marketing of crocidolite and products containing It. In addition, an Approved Code of Practice and Guidance bote on "Work with asbestoa insulation and asbestos coating" was published and case into effect in October 1961. Since 1980 efforts have been made to achieve common standards in the European Cosxunlty on the marketing and use of asbestos products and the protection of the workers in the asbestos industry. Progress has not been as fast as would have been wished. Nevertheless, the possibility of soee agreement la in sight. In view of this the Commission decided on the present action. UCC 008620 More/ The CommlMlen is equally concerned about the public exposure to the hazards of asbestos. However, most measurements of asbestos levels outside the workplace are already considerably below the new control Halts. m As the Advisory Committee said referring to the public health risk., `We conclude that the presence of chrysotlle containing snail quantities of amphlboles is unlikely to have produced any aaterlal Increase In the risk of lung cancer in the general population or any appreciable nunber of cases of aesothelioca. The saae la certainly true of asbestos!*". The Commission will use Its powers to ensure that exposure Units generally regain well below the new Unit and never exceed it. Notes to Editors; 1. The new control Units will Implement Recommendations 14, 15 and 17 of the final Report of the Advisory CoiElttee on Asbestos. 2. The existing control limits are based on guidance that was Issued following the bringing into effect of the Asbestos Regulations 1569. 3. The Advisory Coccittee on Asbestos was set up in hay 1976. Its first two reports, dealing with thermal and acoustic insulation and methods of measulrng airborne asbestos, were published in June 1979. The Final Report of the ACA wss published in October 1979 and the ESC asked for comments. During the consultation period two EC draft Directives on asbestos were published. The first, dealing with marketing and use, was published in hatch 1960 and the second, on the protection of workers, in October 19EC. At its meeting on 17 February 1961 the HSC considered comments received on the AO's Final Report. It also had to. take Into account the proposed EC Directives and the need to co-ordinate Ok and European action on asbestos. The ESC advised the Secretary of State for Employment on 7 April 15S1 on the basis on which an attempt should be cade to reach an agreement in the European Coeaunlcy. 4. The proposed regulations on licensing and prohibition follow the ESC's consideration of responses to the Consultative Documenton the `Asbestos Insulation and Coating Draft Regulations*,intended to implement Recommedstlons 1, 2, 3 and 5 of the ACA's First Report, published in June 1561. 5. A statement by the Chairman of the Commission, hr Bill Simpson, has been Issued today as Press Release C 19 : 82. C 16 : 62 UCC 008621